United States Office of Wastewater EPA-833-B-98-003

Environmental Protection Management (4203) September 1999

Agency

Guidance Manual for the 

Control of Wastes Hauled to 

Publicly Owned Treatment 

Works

U.S. Environmental Protection Agency

Office of Wastewater Management

401 M Street, S.W.

Washington, D.C. 20460
DISCLAIMER

 This project has been funded, at least in part, with Federal Funds from the U.S.

Environmental Protection Agency (US EPA) Office of Wastewater Management under Contract

Number 68-C4-0068, Work Assignment Numbers PS-3-13 (P) and PS-4-13 (P). The mention

of trade names, commercial products, or organizations does not imply endorsement by the

U.S. Government.
CONTENTS

1. INTRODUCTION ................................................... 1-1

1.1 Background .................................................. 1-1

1.2 Purpose of Guidance Manual ..................................... 1-2

1.3 Organization .................................................. 1-3

2. COLLECTING WASTE HAULER INFORMATION, CHARACTERIZING HAULED

WASTE, AND EVALUATING POTENTIAL IMPACTS TO TREATMENT 

PLANTS .......................................................... 2-1

2.1 Collect Waste Hauler Information .................................. 2-1

2.1.1 Identify Waste Haulers Potentially Discharging to the POTW .......... 2-1

2.1.2 Require Waste Haulers to Submit Information ..................... 2-2

2.1.3 Maintain Data and Information ................................. 2-3

2.2 Characterize Hauled Waste ....................................... 2-3

2.2.1 Domestic Waste ............................................ 2-4

2.2.2 Non-Domestic Waste ........................................ 2-4

2.3 Evaluate Potential Impacts to Treatment Plant ....................... 2-12

2.3.1 Potential Impacts to Treatment Plants ........................... 2-12

2.3.2 Determine Potential Impacts From Specific Waste Sources/Types ...... 2-14

2.3.2.1 Determine Whether Waste Meets All Applicable Standards .... 2-17

2.3.2.2 Determine Whether Waste Has the Potential to Cause Pass

Through or Interference ............................... 2-19

2.3.2.3 Determine Whether Waste Has Other Problem Characteristics . . 2-21

3. DEVELOPING AND IMPLEMENTING CONTROLS ....................... 3-1

3.1 Legal Authority ............................................... 3-1

3.1.1 General Authority to Impose Controls ........................... 3-1

3.1.2 Provisions Necessary for Controlling Waste Haulers ................. 3-2

3.2 Active Controls ............................................... 3-4

3.2.1 Controlled Designated Disposal Site ............................. 3-4

3.2.1.1 Access, Hours of Operation ............................. 3-6

3.2.2 Application of Standards and Limits ............................. 3-6

3.2.2.1 Local Limits ......................................... 3-6

3.2.2.2 Categorical Standards ................................. 3-7

3.2.3 Permits ................................................... 3-9

3.2.3.1 Permit Conditions ................................... 3-11

3.2.4 Monitoring Program ........................................ 3-12

3.2.4.1 Sample Types ....................................... 3-13

3.2.4.2 Sampling Frequency .................................. 3-14

3.2.4.3 Testing Parameters ................................... 3-16

3.2.5 Waste Tracking/Manifest System .............................. 3-18

3.2.6 Identification of Illegal Dischargers ............................. 3-18

3.3 Communication .............................................. 3-19
3.3.1 Communication with Other POTWs ............................ 3-19

3.3.2 Communication with Waste Haulers ............................ 3-20

3.4 Review and Update Controls .................................... 3-20

4. CASE STUDIES .................................................... 4-1

APPENDICES

Appendix A Glossary of Terms

Appendix B Bibliography

Appendix C List of State and Regional Pretreatment Coordinators

Appendix D Waste Transporter Authorization Application

Appendix E Summary of Industries Regulated by Categorical Standards and Process

Descriptions

Appendix F Reference Documents with Information on Flammability, Explosivity, and Health

Hazards of Chemicals

Appendix G Hauled Waste Ordinance Language

Appendix H Hauled Waste Manifest Forms

TABLES

Table 2.1 Example Waste Profile Form ........................................ 2-5

Table 2.2 Comparison of Selected Pollutant Concentrations in Domestic Septage and

Domestic Wastewater .............................................. 2-8

Table 2.3 Comparison of Selected Pollutant Concentrations in Domestic Septage and Sewage

Sludge ......................................................... 2-9

Table 2.4 Example Pollutant Concentrations in Landfill Leachate .................... 2-11

Table 2.5 Field Monitoring and Laboratory Instruments ........................... 2-18

Table 3.1 Waste Hauler Ordinance Example Table of Contents ...................... 3-3

Table 3.2 Septage Hauler Monitoring Data .................................... 3-17

Table 3.3 Example Monitoring Parameters for Initial Characterization ................ 3-17

FIGURES

Figure 2.1 Determining Hauled Waste Characteristics .............................. 2-7

Figure 2.2 New or Different Load Decision Flow Chart ........................... 2-16

Figure 3.1 Procedures of a Waste Hauler Permit Program .......................... 3-10
Foreword

Hauled waste may cause adverse impacts to wastewater treatment plants because it is usually

more concentrated than typical domestic wastewater and may not be equalized when discharged. 

Adverse impacts may include pass through, interference, sludge contamination, and hazards to

POTW personnel. To help prevent hauled wastes from causing problems, POTWs need to

adequately control the discharge of hauled waste to their treatment plants.

Many POTWs with pretreatment programs have already developed controls for hauled waste. 

The control of hauled waste at these POTWs can result in the disposal of hauled waste to POTWs

without controls, usually smaller POTWs. This shift in disposal of hauled wastes to smaller

POTWs can result in negative impacts at those plants.

This guidance is designed to provide information for smaller POTWs, generally those without

pretreatment programs, on how to develop and implement hauled waste controls. The guidance

discusses collection of information on waste haulers, characterization of hauled waste received,

evaluation of potential impacts, and the development and implementation of controls. The

guidance also includes case studies of successful waste hauler programs and example forms. 
1-1

Treatment Plant Damaged by Illegal Discharge

On March 23, 1995 a truckload of waste contaminated with solvent was discharged to the Wareham, MA POTW.

The discharge resulted in the emission of toxic fumes to the treatment works in sufficient quantity to threaten

worker health and safety. One plant employee suffered upper respiratory problems.

The solvent-laden discharge caused a major disruption at the treatment plant when it contaminated 90,000 gallons

of sewage, killing half of the microorganisms used to treat the raw sewage. 

The waste hauler was instructed by his supervisor to discharge the contents of the truck to the treatment works.

When he arrived at the receiving station, he filled out a form on which he made false statements concerning the

truck registration number and the waste source.

Source: Associated Press, February 1997

1. INTRODUCTION

1.1 Background

Publicly Owned Treatment Works (POTWs) receive wastewater from a variety of

domestic (household) and non-domestic sources [commercial businesses (restaurants, laundries,

dry cleaners, car washes, etc), and industries]. Smaller POTWs receive mostly domestic

wastewater, while larger POTWs generally receive a more complex mixture of wastewater from a

variety of sources. Most of these wastewater sources are connected to the sewer system and

discharge to the treatment plant through a system of pipes and interceptors. However, wastes

may also be transported by truck or rail to POTWs by waste haulers. Such hauled waste may

include domestic septage, chemical toilet waste, grease and sand trap waste, non-hazardous

commercial and industrial (categorical and non-categorical) waste, hazardous waste, 

groundwater remediation site waste, and landfill leachate.

Because pollutants are usually more concentrated in hauled waste than in typical domestic

wastewater, and because hauled waste may not be equalized when discharged, hauled waste may

cause adverse impacts at treatment plants. These adverse impacts may include pass through to

the receiving water, interference with treatment plant processes and operations, sludge

contamination, and hazards to POTW personnel. To help prevent hauled wastes from causing

problems, POTWs need to adequately control the discharge of hauled waste.
1Any POTW (or combination of POTWs operated by the same authority) with a total design flow greater

than 5 million gallons per day and receiving from industrial users pollutants which pass through or interfere with

the operation of the POTW or are otherwise subject to pretreatment standards.

1-2

POTWs that meet the criteria outlined in 40 CFR 403.8(a)1 are required to develop and

implement an approved pretreatment program. Under 40 CFR 403.5(b)(8), the discharge of

trucked or hauled pollutants is prohibited except at points designated by the POTW. In addition

to designating a discharge point, many POTWs have implemented other controls on the discharge

of hauled waste. These controls include applying limits to non-domestic hauled waste, issuing

permits to waste haulers, implementing tracking systems, sampling loads, and in some cases,

refusing all hauled waste. The control of waste haulers at POTWs with pretreatment programs

can result in the disposal of hauled waste shifting to facilities without pretreatment programs

(“non-pretreatment” POTWs) or to places that are not environmentally suitable. Due to their

small capacities and treatment capabilities, these smaller POTWs are more easily disrupted by high

strength loads. Thus, the result of the shift is an increase in negative impacts to the nonpretreatment POTWS and potentially to receiving water bodies.

Recent studies show an increase of uncontrolled discharges to POTWs without an efficient

program to regulate hauled waste (Thompson and Denow, 1997). Although the vast majority of

waste haulers are reputable business people who provide a valuable service, unscrupulous haulers

may try to dump incompatible wastes on unsuspecting POTWs. Only through efficient controls

can a POTW regulate the volume and makeup of the hauled waste it accepts and protect

treatment plant processes and staff.

1.2 Purpose of Guidance Manual

This guidance manual has been prepared by the U.S. Environmental Protection Agency

(EPA) Office of Wastewater Management to provide guidance on the control of waste hauled to

POTWs. This guidance presents practical information to treatment plant operators and local and

State officials on ways to control the discharge of hauled waste. It is not intended to provide

detailed engineering design information. The specific elements of a waste hauler control program

may vary for each POTW, depending on treatment plant capacity, flows and pollutant loadings,

sensitivity of plant processes, type and amounts of hauled waste accepted, funding, and local
1-3

issues and requirements. Information provided in this manual should be tailored as necessary for

its applicability to an individual POTW.

1.3 Organization

This guidance manual is organized into chapters corresponding to four basic steps to

control waste hauled to POTWs:

1) Collect information on waste haulers potentially discharging to the treatment plant

2) Characterize the hauled waste received in terms of pollutants and concentrations/

loadings

3) Evaluate potential impacts to the treatment plant

4) Develop, implement, and review and update controls, as necessary.

Steps 1, 2, and 3 are described in Chapter 2 which discusses how to collect waste hauler

information, how to characterize hauled waste, and how to evaluate the potential impact of hauled

waste on the treatment plant. Step 4 is discussed in Chapter 3 which includes information on

ensuring adequate legal authority to implement a control program, designating a discharge site,

applying appropriate discharge standards and restrictions, issuing permits, conducting sampling

and analysis, and implementing a tracking system. Chapter 4 provides case studies from actual

POTW programs.
2-1

2. COLLECTING WASTE HAULER INFORMATION, CHARACTERIZING HAULED

WASTE, AND EVALUATING POTENTIAL IMPACTS TO TREATMENT PLANTS

This section discusses Steps 1, 2, and 3 for controlling hauled wastes; i.e., how to collect

waste hauler information, how to characterize hauled waste, and how to evaluate the potential

impact of the hauled waste on the treatment plant.

2.1 Collect Waste Hauler Information

The first step in implementing a hauled waste control program is to identify waste haulers

that may discharge to the POTW. This can be done by conducting a waste hauler survey. The

information gathered will be the basis for characterizing hauled wastes, evaluating the potential

impacts on treatment plant processes, and determining appropriate controls.

2.1.1 Identify Waste Haulers Potentially Discharging to the POTW

The National Pretreatment Regulations [40 CFR 403.5(b)(8)] state that the discharge of

hauled waste is prohibited except at points designated by the POTW. POTW staff can provide

information to and receive information from the majority of waste haulers at this designated

discharge site. However, all haulers may not be aware of or comply with this discharge site

requirement. Therefore, to help identify all potential waste haulers operating in the area

(including those in neighboring jurisdictions) and to identify their mailing addresses, POTW staff

should consult the following sources that might list waste hauler businesses:

• Business license records

• Chamber of Commerce rosters

• Local telephone directories

• Internet searches

• City and State industrial directories

• State/County Health Departments.

In addition, POTW staff can obtain the names and addresses of haulers from the following

sources:

• Businesses identified as having grease traps, sand traps, etc.
2-2

• State lists of hazardous waste generators and treatment, storage, and disposal facilities

(TSDFs).

2.1.2 Require Waste Haulers to Submit Information

An efficient method of gathering information is to require each owner/manager of a waste

hauler business to complete a questionnaire or permit application form. (see Appendix D for an

example application form). POTWs accepting hauled wastes may have obtained basic information

(e.g., name of business, type of waste, and volume) from the truck drivers delivering the waste. 

However, the truck driver may not know all of the information requested on the questionnaire or

application form and may not be the appropriate person to sign the form. An authorized

representative of the company (e.g., decision-level manager or owner) who would know about or

be able to refer you to customer records should complete and sign the questionnaire or application

form.

A letter should accompany the questionnaire or application form stating the purpose of the

form and the deadline for its completion. To boost the response rate, a self-addressed, stamped

envelope can be included. Additional information on the waste hauler program and the names,

addresses, and phone numbers of appropriate POTW staff could also be included with the

questionnaire or application form.

Information Required From All Waste Haulers

Information that POTWs should have on record for all haulers prior to granting approval

to discharge includes:

• Name of business

• Name of owner

• Address and phone number 

• Type(s) of waste hauled

• Estimated number and volume of loads discharged per week for each waste type

• List of non-domestic customers

• Number and capacity of vehicles

• Hours of operation

• Names of other POTWs where hauled waste is discharged

• Where other wastes are disposed (other than those listed above).
2-3

There are 3 questions that the operator

should assess to properly characterize the

hauled waste:

' What is the source?

' What is the general type of waste?

' What are the pollutant concentrations?

Information Required for Each Generator of Non-Domestic Waste

If the hauler serves non-domestic customers (e.g., commercial businesses or industry),

more detailed information should be requested. Information for each waste generator should

generally include the following:

C Name, address, and phone number of the waste generator

C Name of business owner

C Any analytical/physical data collected by the generator or hauler

C Description of waste including waste type, the process generating the waste, frequency

and volume of hauled waste shipments, indication of whether the waste is subject to

federal categorical pretreatment standards, indication of whether the waste is

hazardous as defined in 40 CFR Part 261, and the reason for the waste being hauled to

the treatment plant.

Table 2.1 contains an example waste profile form to collect information from nondomestic waste generators.

2.1.3 Maintain Data and Information

POTWs should establish a system for maintaining waste hauler information including

haulers and their wastes approved for discharge, receipts of hauled waste loads, sampling results

of hauled waste loads, and other relevant information. Maintaining such information will allow

the POTW to track the types and amounts of hauled waste received and may assist in identifying

the source of a waste load that caused problems. Data and information can be maintained in hardcopy form, electronically, or both.

2.2 Characterize Hauled Waste

Before assessing the acceptability of

hauled wastes, the treatment plant operator must

have information on the waste characteristics;

specifically the pollutant concentrations.

Information on the source of the waste and the

general type of waste can provide clues as to

possible pollutants and potential problems. Figure 2.1 provides an overview of the waste

characterization process.
2-4

What is the source, (i.e., residential, commercial business, industry)? If industrial waste,

what type of industry and what specific process created the wastes? If the information is

available, Material Safety Data Sheets (MSD) for specific chemicals and results of any Toxicity

Characteristics Leaching Procedures (TCLP) performed on sludges should be provided as

attachments to the Waste Profile Form (Figure 2.1).

What is the general type of waste, [i.e., domestic waste or non-domestic (non-hazardous

commercial or industrial waste, chemical toilet waste, groundwater remediation site waste, landfill

leachate, or hazardous waste)]? General characteristics of these various types of wastes are

discussed in the following sections. 

What are the pollutant concentrations of Biochemical Oxygen Demand (BOD), Total

Suspended Solids (TSS), metals, toxic organics, flammable or explosive compounds? What are

the percent solids and pH?

2.2.1 Domestic Waste

The majority of waste hauled to POTWs is domestic septage, defined as the liquid or solid

material removed from a septic tank, cesspool, holding tank, or a similar system that receives only

domestic waste (household, non-commercial, non-industrial sewage). Compared to sewage

entering a POTW through a sewerage system, domestic septage is often partially digested and has

higher concentrations of solids and heavy metals, as shown in Table 2.2. In fact, as can be seen in

Table 2.3, domestic septage is more similar, in terms of pollutant concentrations, to sewage

sludge then it is to domestic wastewater.

2.2.2 Non-Domestic Waste

Non-domestic waste may include portable chemical toilet waste, non-hazardous

commercial or industrial waste, groundwater remediation site waste, landfill leachate, or

hazardous waste. Each of these waste types is described below.
2-5

Generator Information (Correspondence will be sent to “Billing Name” address)

Generator Name: Billing Name: 

Street: Street: 

City: State: ZIP: City: State: ZIP: 

Phone: Fax: Phone: Fax: 

Waste Description

Common Name of Waste: 

Process Generating Waste: 

Is the process by which this waste is generated subject to Federal Categorical Pretreatment Standards? [ ] YES [ ] NO

If yes, identify process: 

Is the waste a characteristic or listed hazardous waste defined by 40 CFR Part 261? [ ] YES [ ] NO

Frequency of shipment: 

Waste is: [ ] Industrial Process Waste [ ] Unused or Off-Spec Product

[ ] Commercial Process Waste [ ] UST or Spill-Related Waste

[ ] Food-Related Waste [ ] Other, please specify 

MSD ATTACHED? [ ] YES [ ] NO Comment: 

TCLP ATTACHED? [ ] YES [ ] NO Comment: 

GENERATOR PROCESS KNOWLEDGE CERTIFICATION ATTACHED? [ ] YES [ ] NO

Physical Data (@70EF):

1) Color: 6) Is Waste Pumpable ? [ ] YES [ ] NO

2) Odor: 7) Flash Point [ ] <100 F [ ] 100–139 F [ ] 140–200 F [ ] >200 F

3) Number of Layers: 8) pH [ ] <2 [ ] 1.2–7 [ ] 7.1–12.4 [ ] >12.4

4) Total Solids by Volume: % 9) Specific Gravity: [ ] <1 [ ] 1–1.5 [ ] >1.5

5) Does waste contain free liquids? [ ] YES [ ] NO If yes _____%

Waste Composition:

% %

% %

% Total 100% 

Sample Information

Sample Provided? [ ] YES [ ] NO

If yes, complete the following: Date Collected: Time Collected: 

Sampled by: Grab: 

Composite: Sampling Location:

Table 2.1 Example Waste Profile Form
2-6

Concentration in ppm

INORGANIC CHARACTERISTICS

D004 Arsenic D010 Selenium

D005 Barium D011 Silver

D006 Cadmium Copper

D007 Chromium Zinc

D008 Lead Nickel

D009 Mercury

ORGANIC CHARACTERISTICS

D018 Benzene D032 Hexachlorobenzene

D019 Carbon Tetrachloride D033 Hexachlorobutadiene

D021 Chlorobenzene D034 Hexachloroethane

D022 Chloroform D035 Methyl Ethyl Ketone

D023 o-Cresol D036 Nitrobenzene

D024 m-Cresol D037 Pentachlorophenol

D025 p-Cresol D038 Pyridine

D026 Cresol D039 Tetrachloroethylene

D027 1,4-Dichlorobenzene D040 Trichloroethylene

D028 1,2-Dichloroethane D041 2,4,5-Trichlorophenol

D029 1,1-Dichloroethylene D042 2,4,6-Trichlorophenol

D030 2,4-Dinitrotolune D043 Vinyl Chloride

PESTICIDE/HERBICIDE WARRANTY

I hereby certify the following: The waste identified in Section B of this waste profile form does not contain Endrin,

Methoxychlor, 2,4-D Lindane, Toxaphene, 2,4,5-TP (Silvex), Chlordane, or Heptachlor (and its Epoxide). These

constituents are not used at the location where this waste was generated, nor are they known to be present in the materials of

which the above waste is comprised. Hence, there is no reason to suspect their presence in the waste. Generator’s Initials: 

 

POLYCHLORINATED BIPHENYL (PCB) WARRANTY

I hereby certify the following: The waste identified in Section B of this waste profile form does not contain PCBs at

a concentration of 40 ppm when measured in each container or vessel; that the material is not contaminated with PCBs from

a source containing 50 ppm or greater PCBs; and hereby agree to indemnify and hold harmless from any cost, damages, or

liability resulting from the breach of this warranty. Generator’s Initials: 

HAZARDOUS WASTE WARRANTY

I hereby certify the following: The waste identified in Section B of this waste profile form does not contain any

material at a concentration which would render it as hazardous as defined in 40 CFR 261.3 when measured in each contain

or delivered to and hereby agree to indemnify and hold harmless from any cost, damages, or liability resulting from the

breach of this warranty. Generator’s Initials: 

FEDERAL CATEGORICAL PRETREATMENT STANDARD WARRANTY

I hereby certify the following: (Please circle and initial) The waste identified in Section B of this waste profile form

is/is not generated from a manufacturing process that is subject to Federal Categorical Pretreatment standards; and hereby

agree to indemnify and hold harmless from any cost, damages, or liability resulting from the breach of this warranty. 

Generator’s Initials: 

Name (Print) Title 

Signature Date 
2-7

Source of Waste

Non-domestic* Domestic*

Hazardous Categorical Non-domestic Noncategorical Remedial Site Waste

Reject

z Compare Pollutants/Concentrations to Applicable Limits

Require Pretreatment

or Reject

Does Waste Meet

Categorical Limits?

Does Waste Meet

Local Limits?

Will Waste Cause

Toxic Fumes/Gases,

Flammable or Explosive

Conditions?

Will Waste Cause a Health

& Safety Hazard?

Will Waste Cause

Corrosion or Exceed pH

Limits?

Will Waste Cause Slug

Loading/Interference/ Pass

Through?

Landfill

Leachate

No

Yes Yes

Yes

No

Yes

NoNo

No

YesYesYes

Begin acceptance/

permitting process**

*If a waste load consists of non-domestic anddomestic waste, the load should be considered nondomestic and that branch of the flow chart should befollowed.**Discharge permits should be issued to wastehaulers (see Section 3.2.3) and wasteloads should beproperly manifested.

No

Figure 2.1 Determining Hauled Waste Characteristics
2-8

Table 2.2 Comparison of Selected Pollutant Concentrations in

Domestic Septage and Domestic Wastewater

Pollutant

Domestic Wastewater (mg/l) Domestic Septage(mg/l)

Range Average Range Average

Iron 0.0002 – 3.4 0.989 0.2 – 2,740 39.28

Zinc <0.01 – 1.28 0.212 <0.001 – 444 9.971

Manganese 0.04 – 0.16 0.087 0.55 – 17.05 6.088

Barium 0.04 – 0.216 0.115 0.002 – 202 5.758

Copper <0.005 – 0.61 0.109 .01 – 260.9 4.835

Lead <0.001 – 2.04 0.116 <0.025 – 118 1.21

Nickel <0.001 – 1.6 0.047 0.01 – 37 0.526

Chromium (T) <0.001 – 1.2 0.034 0.01 – 34 0.49

Cyanide 0.01 – 0.37 0.082 0.001 – 1.53 0.469

Arsenic 0.0004 – 0.088 0.007 0 – 3.45 0.141

Silver 0.0007 – 1.052 0.019 <0.003 – 5 0.099

Cadmium 0.00076 – 0.11 0.0008 0.005–- 8.1 0.097

Mercury <0.0001 – 0.054 0.002 0.0001 – 0.742 0.005

Source: Supplemental Manual on The Development and Implementation of Local Discharge Limitations

Under the Pretreatment Program, EPA 1991

Portable/Chemical Toilet Waste

Waste from portable toilets, type III marine sanitation devices, and chemical toilets may be

hauled to the treatment plant for disposal. Hauled waste from chemical toilets may be

incompatible with POTW operations due to antibacterial and disinfecting agents used in the

chemical toilet. Therefore, the POTW should require the hauler to submit information on the

volume and concentrations of bacterial growth inhibitors in the hauled waste and evaluate how

much of this material can be safely handled by the POTW. For example, the Winnipesaukee River

Basin treatment plant requires anyone proposing to discharge portable toilet waste that contains

any chemical first receive approval from the POTW operator to discharge.

Non-Hazardous Commercial/Industrial Waste

Non-hazardous commercial/industrial waste is waste generated by non-domestic sources

that is not regulated as hazardous waste under 40 CFR Part 264. These wastes may include

process wastes, cooling water, boiler blow down, etc.
2-9

Table 2.3 Comparison of Selected Pollutant Concentrations

in Domestic Septage and Sewage Sludge

Parameter

Concentration

Domestic Septage

(mg/kg)

Sewage Sludge

(mg/kg)

Arsenic 4 10

Cadmium 3 7

Chromium 14 120

Copper 140 740

Lead 35 130

Mercury 0.15 5

Molybdenum --- 4

Nickel 15 43

Selenium 2 5

Zinc 290 1,200

Nitrogen as N 2% 2–7%

Phosphorus as P <1% 1–3%

pH 6–7 5–8

Grease 6–12% 5–10%

BOD 6,480 mg/l 2,000 mg/l

Total Solids 3.4% 3–35%

Source: U.S. EPA Domestic Septage Regulatory Guidance, A Guide to the EPA 503 Rule.

September 1993

The National Pretreatment program established categorical pretreatment standards to

regulate the level of pollutants in wastes discharged to POTWs by specific industries. These

standards appear in 40 CFR Chapter I, Subchapter N, Parts 405-471. A summary of industries

regulated by categorical pretreatment standards and descriptions of the regulated processes are

provided in Appendix E. Categorical standards place limitations on the discharge of pollutants

from these industries including toxic pollutants and conventional and non-conventional pollutants. 

Further information on categorical standards and their applicability to hauled waste is contained in

Section 3.2.2.2.

Industrial and commercial wastes which are not regulated by a categorical pretreatment

standard may also be incompatible with treatment plant operations. These wastes can include

wastes from the food processing industry, fats, oil and grease of animal or vegetable origin (e.g.,
2-10

from restaurants), petroleum-based oils (e.g., from auto repair shops, car washes), and a variety

of metal and organic bearing wastes from a variety of industrial and commercial sources. 

Although not subject to categorical standards, these wastes may be subject to local limits. Section

3.2.2.1 contains more information on the development and application of local limits.

Groundwater Remediation Site Waste

Waste from groundwater remediation sites is frequently hauled to POTWs. Most of these

remediation wastes have been treated and contain only trace amounts of toxics that can be

accepted at a POTW without causing problems. However, some remediation wastes may be

discharged at a rate or pollutant concentration that causes pass through or interference. For

example, groundwater remediation waste associated with fuel contaminated groundwater may

contain benzene, toluene, ethyl benzene, xylene, methyl tert-butyl ether, napthalene, petroleum

oils and grease, and lead. POTW operators should require remediation site operators to provide

information on the volume, pollutants, and pollutant concentrations of the waste they propose to

deliver to the POTW. Remediation wastes may also come from Comprehensive Environmental

Response, Compensation, and Liability Act (CERCLA) sites - more commonly referred to as

“superfund” sites. For CERCLA guidance, refer to CERCLA Site Discharges to POTWs

Guidance Manual, EPA 1990 (EPA/542/6-90/005). POTWs are not required to accept wastes

from these cleanup operations and may require the same controls (permitting, application of local

limits, monitoring) on these discharges as would be required on any other wastewater discharge

from another source.

Landfill Leachate

Landfill leachate is a liquid which passes through or emerges from solid waste. Pollutant

concentrations in landfill leachate vary widely, as shown in Table 2.4. Factors which can affect

leachate quality include (Henry and Prasad, 1991 and Lu et al, 1985):

C Type and composition of wastes

C Age of wastes

C Climate and moisture composition of wastes

C Waste processing and compaction and other landfill operational aspects

C Temperature, pH, and redox condition in landfill

C Presence of large quantities of municipal sewage sludge or industrial sludge or wastes
2-11

C Thickness of refuse layer

C Permeability, thickness, compaction, and slope of daily and final cover.

Table 2.4 Example Pollutant Concentrations in Landfill Leachate

Parameter

Range

mg/l

BOD 2,000–30,000

COD 3,000–45,000

TSS 200–1,000

Ammonia Nitrogen 10–800

Chloride 100–3,000

Sulphate 100–1,500

Total Iron 50–600

Alkalinity (as CaCO3) 1,000–10,000

Total Phosphorus 1–70

pH 5.3–8.5 s.u.

Source: Solid Waste Association of North America. Manager of Landfill

Operations Training Course. Course Manual. Publication MSW-D 2360

GMISC 0005. Silver Spring, MD. Revised June 1991.

On February 6, 1998, EPA proposed categorical pretreatment standards for landfills. 

However, these pretreatment standards are applicable only for new and existing hazardous waste

landfills regulated under Subtitle C of the Resource Conservation and Recovery Act (RCRA). 

Pretreatment standards were not proposed for new or existing non-hazardous waste landfills.

Hazardous Waste

Wastes are regulated as hazardous if they are listed as such in 40 CFR 261.31-33 or if they

exceed certain levels of ignitability, corrosivity, reactivity, or toxicity (as defined in 40 CFR

261.21-24). POTWs that accept hazardous wastes by truck, rail, or dedicated pipe within the

property boundary of the plant are considered to be hazardous waste treatment, storage, and

disposal facilities (TSDFs) and subject to RCRA regulations under 40 CFR Part 264. Refer to the

Guidance Manual for the Identification of Hazardous Wastes Delivered to Publicly Owned

Treatment Works by Truck, Rail, or Dedicated Pipe, EPA 1987 for more information.

2.3 Evaluate Potential Impacts to Treatment Plant
2

Pass through is defined as discharge which exits the POTW into waters of the United States in quantities

or concentrations which, alone or in conjunction with a discharge or discharges from other sources, is a cause of a

violation of any requirement of the POTW’s NPDES permit (including an increase in the magnitude or duration of

a violation).

3

Interference is defined as a discharge which alone, or in conjunction with discharges from other sources

both: 1) inhibits or disrupts the POTW, its treatment processes or operations, or its sludge processes, use or

disposal; and 2) therefore is a cause of a violation of any NPDES permit requirement (including an increase in the

magnitude or duration of a violation) or of the prevention of sewage sludge use or disposal in compliance with

applicable statutes, regulations, or permits.

2-12

Even small volumes of toxic or hazardous waste have the potential to impact the treatment

plant. POTW personnel are responsible for assessing the potential impact of hauled waste based

on the waste’s characteristics and the sensitivity of the treatment process. This section provides

information on potential treatment plant impacts and discusses the various determinations needed

to evaluate potential impacts from a specific waste load. 

2.3.1 Potential Impacts to Treatment Plants

The discharge prohibitions in 40 CFR 403.5 apply to all discharges including domestic and

non-domestic hauled waste. Hauled waste has the potential to create a number of impacts at a

treatment plant including pass through2 or interference3, sludge contamination, and worker

hazards. Each of these impacts is discussed in greater detail below.

Pass Through and Interference

Hauled waste can cause slug loadings to POTWs. A slug loading can be attributed to

many different pollutants including BOD, ammonia, phosphorus, metals, and organics. These

loadings may cause interference (i.e., process upset) or pass through. The toxic effects of metals

and toxic organics contained in non-domestic waste hauled to POTWs can interfere with

secondary wastewater treatment processes and sludge treatment processes. In primary

wastewater treatment, solids are removed by sedimentation. These solids are referred to as

primary sludge. Primary sludge is often treated in digesters that utilize bacteria under anaerobic

conditions to render the sludge acceptable for disposal. Toxic metal compounds, particularly

those containing chromium, can destroy these bacteria or inhibit their reproduction, thereby

disrupting the sludge treatment process and producing sludge that cannot be disposed without

additional treatment.
2-13

Bacteria also are used in secondary treatment of wastewater to remove non-toxic organic

wastes. If toxic pollutants affect the bacteria at this stage, the secondary treatment system will

not remove as much of the pathogenic organisms or organic material. Failure of the secondary

treatment system can result in the discharge of incompletely treated wastewater into surface

waters. POTWs are held accountable for National Pollutant Discharge Elimination System

(NPDES) permit violations resulting from pass through and interference, even if the violation was

caused by a waste hauler. If adequate legal authority is available, POTWs should establish

regulations that allow them to enforce against waste haulers and the waste generators in cases

where hauled waste discharges cause pass through or interference. 

Fats, oil, and grease of animal or vegetable origin collected from grease traps and

petroleum-based oils collected from commercial or industrial sources (e.g., from oil/water

separators) are sometimes hauled to POTWs. Fats, oil, and grease of animal or vegetable origin

can be solid or viscous at ambient temperatures and can cause blockages in pipes, clogging of

pumps, and coating and clogging of monitoring probes. In addition, oil and grease from grease

traps may have a pH less than 5. Unlike animal and vegetable oils that can, in a dispersed state,

be treated in aerobic and anaerobic biological systems, petroleum-based oils are degraded slowly

by microorganisms and can reduce treatment efficiency. Accumulation of oil and grease in

anaerobic digesters can reduce the effective capacity of the digesters. If contents are not kept

well mixed and heated, solid scum layers can form and cause blockage in pipes. Because of the

potential problems caused by the discharge of grease trap waste, some POTWs prohibit or place

restrictions on its discharge, both through the collection system and as hauled waste. Other

POTWs have the ability to remove oil and grease (e.g., through discharge to sludge drying beds

or sludge digestion processes) and therefore establish procedures for accepting grease trap waste. 

When determining whether to accept grease trap waste, POTWs should consider the potential for

the waste to cause pass through and interference. At a minimum, POTWs must prohibit the

discharge of oil and grease in amounts that would cause pass through or interference.

Sludge Contamination

Domestic and non-domestic hauled waste can increase the sludge volume generated and

impair sludge settling and dewatering processes. Additionally, toxic metals or organics contained
2-14

in non-domestic waste may settle out with the sludge. This contamination of sludge by toxic

metals or organic compounds may preclude some sludge use or disposal methods (e.g., land

application). If the sludge is disposed in a landfill, these pollutants may leach out and contaminate

adjacent surface and groundwaters. When incineration is used, toxic pollutants may be released

to the atmosphere.

Worker Hazards

Exposure to toxic or hazardous substances in hauled waste can pose dangers to the safety

and health of POTW employees that are in contact with the wastewater. Fires, explosions,

asphyxiation, and poisoning are the lethal effects of certain substances such as solvents, fuels,

strong acids, strong bases, heavy metal chloride and sulfate salts, sodium, calcium, and potassium

salts of strong bases, oxidizing agents, and reducing agents. Other health effects may include:

burns, nausea, vomiting, headaches, fatigue, dizziness, eye, throat, nose, lung, and skin irritations,

respiratory distress including shortness of breath and difficulty breathing, sore throat, and

coughing.

2.3.2 Determine Potential Impacts From Specific Waste Sources/Types

There are several factors to consider when determining whether a specific type of waste or

waste from a particular source has the potential to cause treatment plant impacts. These

determinations include whether the waste meets all applicable standards, whether the waste has

the potential to cause pass through or interference, and whether the waste has other problem

characteristics. Some wastes, such as domestic septage, exhibit relatively consistent properties

and fairly quick determinations can be made as to the likelihood of disruption based on volume

being received and potential concentration of pollutants. However, new or different waste loads

(particularly from non-domestic sources) may also arrive at a facility, and the task of determining

compatibility can be difficult. The flow chart provided in Figure 2.2 provides a representation of

the decision-making process involved in such a situation.
2-15

Permitted waste hauler requests

approval to discharge new or different

type of waste.

POTW reviews manifest and any other

available information to characterize

waste. POTW samples and performs a

quick analysis if necessary.

Do you have enough

information to determine

potential plant impacts?

Is waste compatible?

Determine where in system to

discharge waste and rate of discharge

Discharge waste

Monitor plant performance during

treatment, including sludge. Examine

plant for inhibitions, bad odors.

Document finding for next load of

similar contents.

Refuse to allow

waste to be

discharged

No

Yes

Yes

FIGURE 2.2 NEW/DIFFERENT LOAD DECISION FLOW CHART
2-16

Determine Whether Waste Meets

All Applicable Standards

' Does the non-domestic waste meet

applicable standards (local limits,

categorical pretreatment standards)?

' Will the waste cause toxic fumes/gases,

explosive condition, flammable

condition, corrosive condition, other

hazard to health and safety of POTW

employees?

2.3.2.1 Determine Whether Waste Meets All Applicable Standards

Does the waste meet applicable numerical standards?

If the waste is subject to categorical

pretreatment standards, the waste must meet

the standards prior to discharge to the POTW.

Further information on the application of

categorical standards to hauled waste is

contained in Section 3.2.2.2.

If the POTW applies local limits to nondomestic hauled waste, then the waste must

meet all applicable limits. If a nondomestic waste load exceeds local limits, it should be rejected. More information on the

development and application of local limits is contained in Section 3.2.2.1.

Non-domestic hauled waste may contain pollutants for which there are no numerical local

limits developed. In such a situation, an evaluation of the potential to cause pass through or

interference should be conducted. A discussion of this evaluation is provided below. 

Furthermore, hauled wastes can cause shocks to the treatment system, much like the effects of an

accidental spill or a slug load from the non-domestic users connected to the collection system. 

Therefore, hauled wastes, particularly any new type of hauled waste, should undergo the

evaluation of the potential to cause pass through or interference.

Does the waste meet narrative prohibitions against discharges that cause toxic fumes/gases,

explosive condition, flammable condition, corrosive condition, other hazard to health and

safety of POTW employees?

All non-domestic waste loads should be subject to a visual observation that evaluates the

viscosity, odor, and color. Any unusual characteristics can be noted and further tests conducted if

necessary. The decision for further tests, however, should not be based on the visual observation

alone. The presence of some gases and volatile organics can be detected by smell, but others are

odorless. Some quick and simple monitoring devices that can provide an indication of corrosivity
2-17

and explosivity are a pH meter and an explosivity meter. A pH test should be conducted on all

waste loads from non-domestic sources. An explosivity meter can also be used routinely on all

non-domestic loads, but should always be used on loads suspected of containing chemicals that

can create explosive gases. Both pH and explosivity monitoring devices can be installed at waste

load discharge locations. These devices as well as other field monitoring and laboratory

instruments available are listed in Table 2.5.

Table 2.5 Field Monitoring and Laboratory Instruments

INSTRUMENT MEASURES

WASTEWATER

pH meter Acidity/alkalinity

Oxidation-reduction (redox) meter Oxidation-reduction potential (ORP), measured in

millivolts, is the electrical potential required to

transfer electrons from one compound or element to

another. Negative values indicate a tendency to

reduce compounds or elements and positive values

indicate a tendency to oxidize compounds or elements.

Flashpoint (closed-cup) tester Determines the minimum ambient temperature at

which a substance gives off sufficient vapor to create

an ignitable mixture

AIR

Combustible Gas Detector and Oxygen meter

(CGD/Oxygen explosimeter)

Percentage of oxygen present and the concentration of

combustible gases/vapors present expressed as a

percentage of the lower explosive limit (LEL)

Photoionization detector (PID) Measures the concentration of a variety of organic and

inorganic gases/vapors

Organic Vapor Analyzer (OVA) Can monitor continuously for all detectable organic

vapors or can determine the identity and concentration

of specific organic vapors/gases

Colorimetric tubes Measures concentration of specific gases

Source: Guidance to Protect POTW Workers from Toxic and Reactive Gases and Vapors, EPA 812-B-92-001, June 1992.

The POTW should compile a list of flammable, explosive, corrosive, and toxic chemicals

and compare the chemical analysis of non-domestic waste against the list. If any of the pollutants

in the load are on the list, further tests/analyses could be conducted to determine if the pollutants

are present in concentrations that would pose a threat to the treatment plant processes or

workers. Various reference documents that can provide information on the flammability,
2-18

Determine Whether Wastes Has Potential

to Cause Interference/Pass-Through

' Will the waste cause a slug load or other

interference?

' Will the waste cause the POTW to

violate any NPDES requirements?

explosivity, and health hazards of chemicals can be found in Appendix F. The National Fire

Protection Association, Inc. (NFPA) is a good source for the most current information on

flammable and combustible substances. The American Conference of Governmental and

Industrial Hygienists (ACGIH), the Occupational Health and Safety Administration (OSHA), and

the National Institute for Occupational Safety and Health (NIOSH) all publish information on

hazardous and toxic substances in the work environment. The ACGIH develops occupational

guidelines used by OSHA and NIOSH; these guidelines establish air contaminant exposure limits

known as Threshold Limit Values (TLVs) above which workers should not be exposed. 

Exposure limits have been developed for approximately 650 toxic substances.

2.3.2.2 Determine Whether Waste Has the Potential to Cause Pass Through or

Interference

New sources of non-domestic hauled

waste or non-domestic waste containing pollutants

for which there are no local limits should not be

accepted until the following have been

determined:

Will the waste cause a slug load or other

interference?

Will the waste cause the POTW to violate any NPDES permit requirement (particularly

NPDES effluent limits)?

Answers to these questions are often not easy to determine. Assessing a treatment plant’s

ability to treat a particular waste or determining the actual impacts on the plant is often impossible

due to lack of readily available information. POTW personnel often adopt one of the following

two approaches:

C Refuse – Refuse the waste if it contains pollutants not on an “accepted list” or wastes

that are outside specified boundaries (e.g., pH, specific pollutant concentrations).

C Accept and Watch – Accept the waste and monitor and record any observable impacts. 

If there are no adverse impacts, the POTW continues to accept the wastes. If there
2-19

are any adverse impacts, the POTW rejects any further waste of that nature or

determines what actions may reduce or eliminate the impacts.

Many POTWs believe that the “refuse” approach is the safest way to ensure proper

operation of the treatment plant. If this approach is taken, the POTW should have some

suggested alternatives for the hauler to encourage proper disposal. The “accept and watch”

approach places the POTW in a vulnerable position should the waste cause interference or passthrough (resulting in NPDES permit violations, damage to the treatment plant or receiving water,

or worker health and safety hazards). One way to minimize the risk in accepting non-domestic

waste is to require industry, prior to allowing the discharge, to perform a treatability study.

POTWs accepting non-domestic hauled waste should conduct a technical feasibility

analysis. This analysis is similar to and uses information from the local limits development

process. This analysis should determine whether:

U The POTW has the hydraulic and organic capacity to handle the additional hauled

waste. Determine the unused treatment plant capacity available to handle and treat

hauled waste loadings [the difference between the design or actual capacity (organic

and hydraulic) of the treatment plant and the current and projected sewer collection

system loadings]. Conduct this analysis on each individual unit process (including the

sludge handling and treatment unit processes). Determine the pollutant loading

increases to the effluent, sludge, and air. Compare these increased loadings/

concentrations to any environmental standards (NPDES permit limits, water quality

standards, sludge standards) to determine whether any standards will be exceeded. 

This process is normally performed as part of local limits development. POTWs that

have not developed local limits should contact their Approval Authority (see Appendix

C for a list of contacts).

U The unit operations are suitable for treatment of the pollutants in the hauled waste. 

Determine the pollutant concentrations and loadings that the unit operations can

receive without exhibiting interference. For example, at what loading of TSS, BOD,

or other pollutant does impairment of sludge settling or dewatering occur.

U The POTW has the ability to control feed rates of hauled waste to the treatment plant. 

Determine the sensitivity of treatment plant processes to daily fluctuations in hauled

waste loadings. Systems acclimated to a specific type of waste (pollutants,

concentrations, loadings) can be shocked if waste with different characteristics is

introduced suddenly. Shocks can be prevented if the POTW has the ability to
2-20

Determine Whether Waste Has

Other Problem Characteristics

' Will the waste cause other nuisances

such as objectionable odors, pump or

line clogging, or additional cleaning or

maintenance?

' Does the waste contain bioaccumulative

and persistent substances?

gradually mix this waste with its other incoming wastewater to minimize or eliminate

the fluctuations caused by this waste. The POTW needs to determine when and at

what rate the hauled waste can be discharged to the treatment system. Some POTWs

store the hauled waste and then discharge it during off peak loading times while other

POTWs discharge hauled waste during times of high hydraulic but low organic

loading.

2.3.2.3 Determine Whether Waste Has Other Problem Characteristics

Hauled waste may constitute a small

percentage of the volume and pollutant loadings

of a POTW and when the discharge feed rate is

carefully controlled, interference and pass

through may never occur. However, the hauled

waste may create operation and maintenance

problems that result in increased treatment costs

and greater deterioration of equipment and

facilities. A POTW should determine whether it is providing an environmentally sound treatment

service or whether it is acting as an agent that dilutes and transfers the pollutants to other media

such as the receiving stream, air, or sludge.

Will the waste cause other nuisances such as objectionable odors, pump or line cloggings,

foaming aeration tank/aerated digester, or additional cleaning/maintenance requirements?

A variety of problems have been associated with domestic and non-domestic hauled

wastes:

C Increased volume of grit, scum, and screenings

C Increased volume of primary and secondary sludge

C Increased phosphorus load

C Bulking of activated sludge

C Difficulty in sludge thickening and dewatering

C Excessive foaming.

Does the waste contain bioaccumulative and persistent substances that are not amenable to 

treatment?
2-21

If the waste contains bioaccumulative and persistent substances (e.g., mercury, PCBs), the

POTW may want to handle these wastes in a fundamentally different manner because even very

small amounts could cause a violation of a water quality standard, and these persistent substances

could accumulate in downstream sediments, flora, and fauna that may require future remediation.
3-1

3. DEVELOPING AND IMPLEMENTING CONTROLS

To avoid complications caused by discharges of waste hauled to a POTW, all POTWs that

receive hauled wastes should implement a program to control hauled waste. Prior to

implementing a control program, POTWs should first review and revise their legal authorities, as

necessary, to ensure that adequate legal authority is available for all proposed controls. Legal

authority is discussed in greater detail in Section 3.1 Waste hauler control programs could

include active control mechanisms and communication. Active controls include designating

disposal sites, conducting monitoring, applying appropriate discharge limits, issuing permits,

implementing a tracking system, and identifying illegal discharges. Communication includes

communicating with waste haulers and with other POTWs. Active controls and communication

are discussed in more detail in Sections 3.2 and 3.3. Controls implemented by a POTW should be 

tailored for the treatment works’ specific operating conditions and needs and should be reviewed

and updated, as necessary.

3.1 Legal Authority

3.1.1 General Authority to Impose Controls

Legal authority needed to control the discharge of hauled waste includes the general

authority to impose controls (i.e., state law and local ordinances) and specific ordinance

provisions applicable to hauled waste.

The legal authority of a POTW or other local authority to administer controls on hauled

waste or to implement a hauled waste permit program is derived from State law and local

ordinances. If adequate legal authority to control hauled waste is not present, local ordinances

should be modified. State law determines what authorities a POTW may possess; thus, the

POTW must be aware of these laws when developing or seeking modifications to its local

ordinance. The local ordinance must describe all of the controls in sufficient detail so that waste

haulers and POTW personnel will understand the procedures, expectations, and liabilities

associated with the program. The POTW should request its attorney to assist in reviewing the

ordinance to ensure that it provides adequate authority and that the ordinance does not create any

unnecessary procedural or institutional obstacles which might hinder the discharge control
3-2

programs. Depending on their legal authority, POTWs can regulate the waste generator, the

waste hauler, or both. If a POTW accepts non-domestic hauled waste from outside its

jurisdiction, it should ensure that it has the legal authority to regulate those waste generators

located outside its jurisdiction.

3.1.2 Provisions Necessary for Controlling Waste Haulers

The legal authorities required for an effective waste hauler control program are similar to

those for regulating sources connected to the POTW; however, there are certain additional

provisions which should be included in the POTW’s sewer use ordinance. In particular, the

ordinance should contain the following provisions:

C Prohibition on the discharge of hauled waste, except at points designated by the

POTW.

• The hauled waste must meet all applicable federal, State, and local pretreatment

standards and requirements including categorical standards developed for the waste

generator’s industrial category. If the POTW’s legal authority allows it to do so, the

ordinance should also be expanded to allow the POTW to permit and regulate the

generator of non-domestic hauled wastes.

• The POTW may require commercial, industrial, and/or residential waste haulers to

obtain a permit.

• The POTW may collect samples of each hauled load to ensure compliance with

applicable pretreatment standards.

• No load may be discharged without prior consent of the POTW.

• The POTW may require the hauler to provide a waste analysis of any load prior to

discharge.

• Requirement that waste haulers must use a manifest system.

C Penalties for violating the ordinance or permit.

Table 3.1 provides an example table of contents for a waste hauler ordinance. Examples

of waste hauler provisions are provided in Appendix G.
3-3
3-4

SECTION 1 – GENERAL PROVISIONS

1.1 Purpose and Policy

1.2 Administration

1.3 Definitions

SECTION 2 – HAULED WASTE PERMIT APPLICATION

2.1 Application Required

2.2 Re-Application Required

2.3 Application Signatories and Certification

SECTION 3 – HAULED WASTE PERMITS

3.1 Permit Required

3.2 Permit Contents

3.3 Permit Decisions

3.4 Permit Transfer

3.5 Permit Modifications

3.6 Permit Revocation

SECTION 4 – GENERAL HAULED WASTE/TRANSPORTER REQUIREMENTS

4.1 Prohibited Discharge Standards

4.2 Limitations for Authorized Disposal of Specific Wastes

4.3 POTW Hours of Operation/Contact Information

4.4 Liquid Waste Vehicles Maintenance/Operations

SECTION 5 – REPORTING REQUIREMENTS

5.1 Manifests Required

5.2 Self-Monitoring Reports

5.3 Reports of Changed Conditions

5.4 Reports of Potential Problems

5.5 Notice of Violation/Repeat Sampling and Reporting

5.6 Analytical Requirements

5.7 Sample Collection

5.8 Timing

5.9 Record Keeping

SECTION 6 – COMPLIANCE MONITORING

6.1 Right of Entry: Inspection and Sampling

6.2 Search Warrants

SECTION 7 – CONFIDENTIAL INFORMATION

SECTION 8 – SUPPLEMENTAL REQUIREMENTS

8.1 Performance Bonds

8.2 Liability Insurance

8.3 Surety Bonds

8.4 Public Nuisances

8.5 Informant Rewards

SECTION 9 – MISCELLANEOUS PROVISIONS

9.1 Pretreatment Charges and Fees

SECTION 10 – EFFECTIVE DATE

Table 3.1 Example Table of Contents for Waste Hauler Ordinance 
3-5

3.2 Active Controls

Active controls for hauled waste programs include designating and controlling access to

disposal site, applying limits and standards, issuing permits, monitoring, manifesting/tracking

waste, and identifying illegal discharges. Each of these is activities is discussed below.

3.2.1 Controlled Designated Disposal Site

Choosing a Site

Under Federal Regulations [40 CFR Part 403.5(b)(8)], POTWs must prohibit the

discharge of any trucked or hauled pollutants except at discharge sites designated by the POTW. 

Therefore, POTWs accepting hauled waste must designate a specific discharge point. Some

POTWs specify discharge sites that are located at the treatment plant while others allow hauled

wastes to be discharged at remote sites within the collection system (e.g., manholes or pump

stations). POTW operators may have to make a difficult decision concerning discharge site

location. Factors to consider when designating the location of a discharge site include sensitivity

of the treatment plant to pollutant loadings from hauled waste discharged directly to the

headworks of the treatment plant, accessibility to the discharge site, and visibility of the site to

POTW personnel (i.e., the ease of surveillance). Generally, the further “upstream” a discharge

site is from the headworks of a facility, the longer the waste has to mix with other wastewater that

may equalize and dilute it, creating less chance for plant disruption. However, some treatment

plants have holding facilities that allow hauled waste to be collected and stored for discharge to

the plant when influent plant loadings are lowest. Other treatment plants provide equalization

basins that allow hauled waste to be mixed and equalized with influent wastewater, thus allowing

the operator to better control flow and loadings to the headworks. In addition to equalization,

remote sites may allow waste haulers easier access and may reduce the traffic flow within the

treatment plant. However, control over a remote site is more difficult and possibly more costly if

personnel need to be stationed at the site, or if the installation of gates or surveillance devices

(such as cameras) becomes necessary.

If hauled waste is discharged at the treatment plant, discharge to the headworks is

generally preferred. This allows for screening and grit and grease removal. Hauled waste
3-6

receiving stations located at the treatment plant may include an unloading area, a receiving/

storage tank, and transfer pumps.

The following factors should be considered in designing the receiving station:

• Speed Limits on POTW Roads—Speeds should be posted clearly to ensure the safety

of the haulers and POTW personnel.

• Sight Lines—Blind curves and corners should be avoided. Particularly dangerous

areas should be clearly indicated with appropriate signs.

• Wear on Roads—The constant wear from trucks may increase maintenance costs if

access roads are not properly designed.

• Vehicle Access—Adequate space should be allowed for vehicles to back-up if a pullthrough station is not used. Providing access and explicit instructions for recreational

vehicles should also be considered, if these types of vehicles are expected to use the

station.

• Security and Visibility—The receiving station should have limited access (e.g., have

locked gates and access cards). The receiving station should also be clearly visible to

POTW personnel or monitored through cameras to ensure that the POTW is aware

when a truck is entering to dump.

• Surface and Slope of Discharge Area—The discharge area should be constructed of

a hard surface material and the discharge location should be graded so that it slopes

toward the catchment. This will help empty the entire truck as well as keeping the site

clean and dry, and will allow storm water coming into contact with the pavement

around the discharge location to be directed towards the catchment.

• Receiving Tank—The receiving tank should have a sloped bottom equipped with a

drain sump to provide for complete draining and cleaning.

• Pumps—The type of pump required may vary depending on the types of hauled waste

accepted. In general, pumps used to handle hauled waste handling should be nonclogging and capable of passing 3-inch diameter solids.

• Number of Catchments—Offering more than one catchment can help in reducing the

number of trucks waiting to discharge.

• Odor—Due to the odorous nature of many hauled wastes, the discharge location

should be sited so as not to be problematic for plant personnel or nearby residents and

businesses.
3-7

• Clean-Up—A water hose should be provided for clean-up of the unloading station, as

well as to wash off the truck. Chlorinated treatment plant effluent may be considered

for this use. Wash waters should be directed toward the catchment.

3.2.1.1 Access, Hours of Operation

Controlling access to a discharge site can greatly reduce the possibility of facility

disruption by illegal or incompatible discharges. Manual locking gates can be installed at the site

entrance. Several facilities are now equipped with an electronic card access system. Permitted

haulers are given an electronic “credit” card which serves as a key to the facility, and which may

also be used for waste hauler tracking and billing. One potential drawback to such a system is

that cards may be “lent” to unpermitted haulers.

When determining hours of operation and discharge time limitations, POTWs should

consider the times when POTW personnel are available and the times during the day that peak and

low flows occur within the collection system and within the treatment plant. This is especially

true for smaller POTWs where peak and low flows may be of particular concern. Twenty-fourhour access is an option which may be appropriate for some facilities (e.g., facilities that are

staffed at all times). Twenty four hour access may increase the period of time between discharges 

and increase flexibility for septage haulers.

3.2.2 Application of Standards and Limits

As discussed in Section 2.3.2, non-domestic hauled waste may be subject to local limits

and/or categorical pretreatment standards. The applicability of local limits and categorical

pretreatment standards to non-domestic hauled waste is discussed below.

3.2.2.1 Local Limits

POTWs with approved pretreatment programs are required to develop and enforce local

limits for pollutants of concern. Many non-pretreatment POTWs also developed local limits

independently or may have been required to develop local limits if pass through or interference

has occurred or is likely to occur. Local limits are intended to prevent interference, pass through,

sludge contamination, and worker health and safety problems. The process of local limits

development generally includes collecting monitoring data (e.g., influent, process effluent,
3-8

effluent, sludge, domestic, hauled waste, and industrial user) to characterize existing pollutant

loadings, determining applicable environmental criteria, identifying pollutants of concern, and

determining the Maximum Allowable Headworks Loading (MAHL) for each identified pollutant

of concern. Maximum Allowable Industrial Loadings (MAILs) are then determined from the

MAHLs by allowing for a safety factor and subtracting loadings from uncontrolled discharges

(e.g., domestic and commercial loadings). Finally, the MAILs are allocated to industrial users as

local limits.

Local limits do not apply to hauled domestic waste. However, pollutant loadings from

hauled domestic waste should be accounted for in local limits development. Pollutant loadings

from hauled waste should be determined and these loadings should be subtracted from the MAHL

(along with domestic wastewater and other uncontrolled loadings) when determining MAILs. 

Alternatively, POTWs could allocate a portion of each MAIL to waste haulers and thus develop

limits applicable to hauled waste.

For more information on the development of local limits, in general, refer to the Guidance

Manual on the Development and Implementation of Local Discharge Limitations Under the

Pretreatment Program, EPA 1987 (833-B-87-202-1). For specific policies and procedures on

local limits development, POTWs should contact the Approval Authority in their State or EPA

Region. A list of contacts is contained in Appendix C.

3.2.2.2 Categorical Standards

Categorical pretreatment standards are contained in 40 CFR Parts 405-471. Categorical

Pretreatment Standards are standards published by the EPA for the different categories of

industrial users. These standards are published in accordance with Section 307(b) and (c) of the

Clean Water Act (CWA). EPA has issued categorical pretreatment standards that are: (1)

concentration - based, (2) production-based, or (3) both. A summary of industries regulated by

categorical pretreatment standards and descriptions of the processes performed by these industries

are provided in Appendix E.
3-9

To determine if wastes collected by haulers are regulated by National categorical

pretreatment standards, the POTW should obtain information from both the waste hauler and the

waste generator. Questions that might be asked by the POTW to determine applicability of any

National categorical pretreatment standard might include the following:

• Why does the generator want to haul the wastewater to the POTW (e.g., a generator

located on a septic system)?

• Were the wastes generated from regulated processes subject to categorical

pretreatment standards? If so, what are the volumes of each process wastestream

making up the total hauled load? If a POTW is uncertain about the applicability of

categorical standards, it should request a description of activities conducted and

wastewater generated at the facility in question.

• What types of pollutants are known or suspected to be present in the hauled wastes? 

At what estimated or known levels?

• If the hauled waste is subject to categorical pretreatment standards, is it in compliance

with the standards? Monitoring records should be obtained to verify compliance. If

the waste is subject to production-based standards, production data should also be

obtained.

• Did the waste hauler collect wastes from more than one location or source such that

domestic and industrial or different types of industrial wastes have been mixed within

the load? To allow the POTW to determine compliance with categorical pretreatment

standards, hauled waste loads subject to categorical standards should not be mixed

with other wastes prior to discharge.

• Is the waste hazardous under the RCRA? If so, is it a listed or a characteristic waste? 

More information on accepting hauled hazardous waste is provided in EPA’s

Guidance Manual for the Identification of Hazardous Wastes Delivered to Publicly

Owned Treatment Works by Truck, Rail, or Dedicated Pipe (June 1987).

Categorical pretreatment standards apply to waste generated by categorically regulated

processes, whether the waste is discharged through the sewer system or hauled to the POTW. 

The generator of categorical waste is responsible for complying with all associated monitoring

and reporting requirements. POTWs with approved pretreatment programs and adequate legal

authority can act as the Control Authority and regulate the generators of categorical waste that is

hauled to the POTW. These POTWs should ensure that adequate legal authority is available to

regulate all categorical hauled waste generators discharging to the POTW, including those located
3-10

outside the POTW’s jurisdiction. POTWs that do not have an approved pretreatment program or

that do not have adequate legal authority to regulate hauled waste generators directly, should

notify the generators that monitoring reports must be submitted to the Control Authority (the

State or EPA in states without delegated pretreatment programs). In this case, the POTW should

obtain copies of all reports submitted to the Control Authority. 

3.2.3 Permits

A permit system is the most direct and efficient method of regulating waste haulers that

discharge to a POTW. Implementing a permit system provides the opportunity to monitor and

regulate haulers based on the treatment works’ operating conditions. Figure 3.1 presents an

overview of procedures involved in implementing a waste hauler permit system. If a POTW

accepts hauled industrial waste (including wastes regulated by categorical pretreatment

standards), it should also consider permitting the waste generator as well as the waste hauler.

All waste haulers within the immediate and surrounding service area should be considered

potential dischargers to the POTW system and should be notified of the permit system

requirements, including the prohibition against discharge of hauled waste except at designated

areas. Notification could be provided individually to each waste hauler that potentially could

discharge to the POTW, or notification could be accomplished through general procedures such

as publishing notices in newspapers or trade papers. However, if a POTW’s local sewer use

ordinance prohibits the discharge of hauled waste without a permit, any hauler that discharges

without a permit is in violation and subject to all liability whether or not they received notification

of permit requirements.

As discussed in Section 2.1, each waste hauler should be required to complete a

questionnaire or permit application. The permit application form should be designed to provide

the POTW with all information necessary to identify, track, communicate with, and control waste

haulers. A sample waste hauler’s permit application is presented in Appendix D. 
3-11

POTW notifies waste hauler of

permit system requirements

Waste hauler applies for a

discharge permit.

Application

Approvable?

POTW approves permit application

and issues a discharge permit with

applicable limits and conditions.

Waste hauler collects

customer waste.

Waste hauler records entry

on manifest form

Waste hauler provides copy of manifest

and any sampling results collected by the

waste generator or hauler to POTW at

time of discharge

Waste hauler discharges to POTW

POTW samples

and inspects

waste hauler

loads

POTW rejects

hauled waste

load

Waste hauler

does not apply

for permit

POTW prohibits

the discharge of

hauled waste

from the hauler

No

Yes

Yes

FIGURE 3.1 PROCEDURES OF A WASTE HAULER PERMIT PROGRAM

No

Load complies

with applicable

limits
3-12

3.2.3.1 Permit Conditions

The following is a list of conditions that a POTW should consider including in discharge

permits issued to waste haulers:

• Right of Refusal to Accept Waste—The POTW should maintain the right to refuse

any hauled waste load.

• Non-Domestic Loads—The waste hauler should be limited to discharging only

domestic waste if the POTW is not capable of treating hauled nondomestic wastes. 

However, if a POTW can treat nondomestic wastes in general, or only certain

nondomestic wastes, then provisions for these discharges should be established. To

account for the nondomestic wastes it receives from waste haulers, the POTW should

require a list of customers from each hauler and the type(s) of waste(s) hauled from

each customer.

• Prohibited Discharges—Waste haulers must always be prohibited from discharging

wastes which would violate any prohibited discharge standards of the General

Pretreatment Regulations [40 CFR 403.5 (a) and (b)] or any local prohibited

discharges. The POTW may wish to sample and analyze the hauled wastes or require

that the hauler perform such sampling and analysis to verify that such standards would

not be violated if the waste is discharged to the POTW. If the POTW does not have

permit-by-rule status, or is not otherwise equipped to treat RCRA hazardous waste,

the permit should prohibit the introduction of hazardous waste to the POTW.

• National Categorical Pretreatment Standards—If waste haulers are allowed to

discharge nondomestic wastes to the POTW, then it should be determined whether the

sources of these waste are regulated by national categorical pretreatment standards. If

a hauler discharges categorical process wastewater, the permit must require

compliance with applicable categorical standards.

• Local Limits—The permit should require compliance with any local limits established

by the POTW, including any specific limits applicable to hauled non-domestic waste.

• Designated Disposal Site—The permit should clearly designate the disposal site and 

state all facility rules for discharging such as clean-up requirements.

• Number of Loads—If a POTW is susceptible to hydraulic or organic overloading, it

may wish to consider placing a limit on the maximum number of loads that a waste

hauler can discharge over a specified period of time.

• Time Limitations—Specific days and/or hours that waste haulers are allowed to

discharge should be stated in the permit conditions.
3-13

• Waste Tracking/Manifest System—The permit should contain a condition that

requires the waste hauler to provide documentation on the nature, origin, and volume

of the wastes being discharged. Refer to Section 3.2.5 for more information.

• Notification of Waste Type—The POTW may want to require that any waste be

approved prior to being hauled. The permit should require the hauler to notify and

receive approval from the POTW of new customers as well as changes in the nature of

wastewater originating from existing customers. Under 40 CFR 403.12(j), industrial

users are required to notify the POTW of any substantial changes in the volume or

character of pollutants discharged. POTWs should require this same notification from

waste haulers that discharge industrial wastewater.

• Standard Conditions—Many of the standard conditions placed in other industrial user

permits should also be contained in waste hauler permits. A few of these are:

modification of conditions, non-transferability, revocation of permit, and penalties/

fines. The POTW could also consider requiring waste haulers to post a performance

bond.

C Significant Industrial User—If a waste hauler meets the definition of significant

industrial user [40 CFR 403.3(t)] and the POTW has an approved pretreatment

program and adequate legal authority, the POTW should permit the waste hauler as a

significant industrial user and the permit must include all conditions required under 40

CFR 403.8(f)(1)(iii) 

For more information on permitting procedures, refer to the Industrial User Permitting

Guidance Manual, EPA 1989.

3.2.4 Monitoring Program

Monitoring is necessary to gather information about the characteristics of hauled waste

that is discharged to the treatment plant, and to determine if waste should be rejected because of 

potential negative impacts to the facility. Monitoring is also necessary to ensure that discharges

conform to appropriate standards and regulations. A monitoring program can provide

information on which load and what pollutants and concentrations caused problems in plant

operations. A monitoring program demonstrates to the waste haulers that the POTW is serious

about enforcing the standards and requirements of its hauled waste control program. For these

reasons, POTWs should seriously consider including monitoring as part of their waste hauler

control program, particularly if non-domestic wastes are accepted.
3-14

The POTW or the waste hauler could sample the non-domestic waste at the location

where it is generated before it is pumped into the truck or rail car. A seal can be placed over the

truck’s discharge point which, upon arrival to the POTW, can be inspected to ensure that no other

wastes had been introduced to the truck since sampling. Sampling may also be performed at the

discharge site.

3.2.4.1 Sample Types

Decisions on whether to accept a load of non-domestic waste may be based on incorrect

information if sampling is not performed properly. Proper techniques, as found in 40 CFR Part

136, must be used for sample collection, preservation, storage, and analysis if reliable results are

expected to be obtained. The following conditions are important to consider for any sampling

program.

There are two basic types of samples: grab samples and composite samples. For sampling

hauled waste, both sample types are collected manually. Selection of sample type to collect

depends on several key factors including:

• Composition of the waste that is being received

• Pollutants to be analyzed

• Physical setup of the receiving station

• Purpose of the sample

• How well mixed the load is

Grab Sampling

A grab sample is a single discreet sample collected over a short period of time without

regard to the waste stream flow. Grab samples are useful in taking a “snapshot” of a discharge

and can provide information on the extreme pollutant concentrations of a load, whereas

composite sampling may mask the extreme pollutant levels. Grab samples may be used if both

flow and pollutant concentrations or loadings are constant and should only be employed if the

POTW operator has determined the waste contained in a hauler’s truck is homogeneous. Grab

sampling is used when collecting composite samples is not appropriate. For example, grab

sampling is necessary for such parameters as pH, oil and grease, temperature, total phenol,

cyanide, sulfides, and volatile organics.
3-15

Composite Sampling

Composite samples measure the average amount of pollutants discharged by a waste

hauler during the entire discharge period. A composite sample is a mixed or combined sample

that is formed by combining a series of individual and discrete grab samples collected over a

period of time or representing more than one specific location or depth.

Composite sampling of hauled waste consists of collecting time-proportional samples at

specified intervals during a discharge. For a non-homogeneous discharge, wastes are stratified in

the hauler’s tank and the effluent quality will vary over the discharge period. For this situation,

the composite sample collected over the discharge period would be most appropriate. Grab

samples should be taken at least three times during the discharge and then composited: once at the

onset of the discharge, where a higher concentration of solids are likely to occur, once in the

middle of the discharge, and once at the end of the discharge where light oils are most likely to

appear.

3.2.4.2 Sampling Frequency

The POTW should consider a number of issues when establishing sampling frequency,

including:

• Frequency necessary to obtain data representative of the nature and volume of the

hauled waste

• Frequency necessary to deter unscrupulous haulers from delivering and discharging

incompatible wastes

• Actual (or potential) impact of the hauled waste on the operation of the treatment

plant, receiving water body, and sludge disposal practices

• The hauled waste source and the types and concentrations of pollutants contained in

the waste

• Regulatory requirements of any permits, local ordinances, POTW policies, and federal

regulations

• Seasonal variations in the volume and makeup of hauled waste

• Availability of POTW staff
3-16

Automatic pH Testing

A POTW in Fairfax County Virginia has recently installed a fully

automatic pH screening discharge facility. Wastes are discharged

to an underground temporary holding tank, and automatically

tested for pH. If the load is acceptable, waste haulers record the

reading from a meter into a daily log. If the pH is too high or too

low, the waste is held and POTW personnel are notified by an

alarm. The waste is tested once again, and if found to be

incompatible, pumped back into the truck.

• Trends in delivery times

• Compliance history of the waste hauler

• Expense of sampling and analysis imposed on both the waste hauler, the POTW, and

the resources (labor and equipment) available.

The POTW should establish a base sampling frequency and increase or decrease the

frequency on a case-by-case basis using the factors discussed above. A base sampling program

for non-domestic waste should, at a minimum, include:

C Visual observation and recording of any unusual odors, color, or other characteristics

C Monitoring of pH

C Collection of a grab or composite sample of the hauled waste.

While an effective deterrent,

sampling alone may not provide

complete protection from incompatible

loads, as it can provide information

only if analyzed. Treatment plant

operators may find the need to perform

a quick analysis of a load before

discharging to the headworks for any number of pre-determined or suspect parameters. Analyzing

for pH is perhaps the most effective way to discover incompatible loads, and can be performed

rapidly, without great cost to the POTW or the waste hauler.

Example sampling programs that have been developed by POTWs are described below:

• Comprehensive sampling and analysis of all non-domestic hauled waste and

periodic sampling and analysis of domestic septage—All hauled wastes of Nondomestic origin are sampled and analyzed and every tenth load of domestic septage

received from each hauler is sampled and analyzed.

• Comprehensive sampling of all hauled wastes and periodic or random analysis of

the collected samples—A sample is collected from each hauled waste load. These

samples are preserved and stored and a portion of the samples are analyzed. Each

hauler knows that all of his loads will be sampled but does not know which of his loads

will be analyzed. In addition, if a disruption in plant operations occurs, the stored

samples can be used to determine the exact makeup of the load which caused (or is
3-17

suspected of causing) the disruption. If several loads were received, the stored

samples of all these loads can be analyzed to assist in identifying the waste hauler and

waste load that may have caused the disruption.

• Random sampling and analysis—Sample collection and analysis are conducted on a

random basis. For example, the POTW randomly selects a day to conduct sampling

and all waste loads that are received that day are sampled and analyzed, or the POTW

may collect and analyze samples every day but randomly selects the loads to be

sampled and analyzed (i.e., every fifth truck or seven random samples per day).

3.2.4.3 Testing Parameters

Testing parameters should be determined in two phases. First, if not already completed,

the POTW should characterize the wastes it commonly receives to obtain typical pollutant levels. 

This initial characterization may take place over a period of several months to more than a year.

Secondly, pollutants of concern identified in the initial phase should be specified as the parameters

for a routine monitoring program.

Existing septage hauler monitoring data may be useful to identify pollutants potentially

discharged by waste haulers. Table 3.2 summarizes septage hauler monitoring data provided by

nine POTWs. Metals identified at highest average levels in septage haulers’ loads included iron,

zinc, copper, lead, chromium, and manganese. The most frequently identified metals were

copper, nickel, chromium, and lead. Organics identified at highest average levels were acetone,

isopropyl alcohol, methyl alcohol, and methyl ethyl ketone. Based on these data, POTWs should

anticipate that hauled septage may contain relatively high levels of heavy metals and organic

solvents. However, the type and level of pollutant present will vary depending on the type of

hauled waste (e.g., domestic septage, landfill leachate, groundwater remediation site waste,

industrial wastes). POTWs should periodically monitor septage haulers’ loads to determine site

specific pollutant concentrations and loadings for those metals listed above, as well as for

common organic solvents (especially ketones and alcohols) and any other identified pollutant of

concern. Table 3.3 provides example monitoring parameters for initial characterization of these

various types of hauled wastes.
3-18

Table 3.2 Septage Hauler Monitoring Data

Pollutant

Domestic Septage(mg/l)

Minimum Maximum Average

Iron 0.2 2,740 39.28

Zinc <0.001 444 9.971

Manganese 0.55 17.05 6.088

Barium 0.002 202 5.758

Copper .01 260.9 4.835

Lead <0.025 118 1.21

Nickel 0.01 37 0.526

Chromium (T) 0.01 34 0.49

Cyanide 0.001 1.53 0.469

Arsenic 0 3.5 0.141

Silver <0.003 5 0.099

Cadmium 0.005 8.1 0.097

Mercury 0.0001 0.742 0.005

Source: Supplemental Manual on The Development and Implementation of Local

Discharge Limitations Under the Pretreatment Program, EPA 1991

Table 3.3 Example Monitoring Parameters for Initial Characterization

Type of Hauled Waste Initial Characterization

Leachate from nonhazardous waste disposal

sites

BOD, TSS, oil & grease, total Kjeldahl nitrogen (TKN),

ammonia, iron, manganese, pH, phenols, phosphorous,

chlorides, Total Dissolved Solids (TDS), all priority

pollutants except 2,3,7,8 tetrachlorodibenzo-p-dixon and

asbestos.

Leachate from hazardous waste disposal sites BOD, TSS, oil & grease, TKN, ammonia, iron, manganese,

pH, phosphorous, chlorides, TDS, all compounds on the

Superfund Target Compound List and any other known or

suspected contaminants identified by an investigation of site

or by gas chromatograph/mass spectrophotometer (GC/MS).

Fuel contaminated wastewater Benzene, toluene, ethyl benzene, xylene, methyl tert-butyl

ether, naphthalene, oil & grease, pH, and lead

Groundwater remediation site (not associated

with fuel contamination)

Determine from the groundwater remediation investigation

Categorical industrial discharge All categorically regulated pollutants

Septage 1 sample for BOD, TSS, pH, oil & grease, and metals and

organics of concern

Source: New York State Department of Environmental Control (NYSDEC) Technical Operational Guidance (TOGs) for

Acceptance of New Discharges, October 1994
3-19

3.2.5 Waste Tracking/Manifest System

A manifest system, similar to those used for hazardous waste, is an efficient means to

record information on hauled waste. This type of control can be employed independently of a

permit system. Examples are provided in Appendix H of this document. This type of system

requires waste haulers to enter information on the waste manifest form for each load received. 

The manifest form should include information such as:

C Name, address and phone number of hauler and each waste generator

C Types of wastes collected from each generator

C Approximate volume(s) received by the hauler

C Known or suspected pollutants, identified by the generator

C Certification by the generator that the waste is not hazardous and whether it is

generated from any process that is defined as a categorical process wastewater

C Results of any testing performed on the wastewater.

Prior to each discharge, the POTW should require a completed manifest form from the

waste hauler. Each manifest sheet should be completed in triplicate: one copy for the waste

hauler, one copy for the treatment plant operator, and one copy for the POTW’s administrative/

billing purposes. The POTW should supply blank manifest forms to each waste hauler. 

Treatment plant operators should periodically verify the information provided on the manifest

form by contacting the sources provided on the manifest.

3.2.6 Identification of Illegal Dischargers

Identification of a waste hauler as the source of pass through or interference can be a

difficult task. Hauled waste can be discharged to a manhole and the hauler gone before the waste

reaches the treatment plant. There are several examples where hazardous waste haulers have paid

industries for the seclusion their facility provides during such illegal discharge events. 

Approaches to help alleviate the problem include:
3-20

Treatment Facilities Lose $1.28 Million

In 1996, six former and present officials of one of the nation’s largest waste hauling firms were indicted on

Federal charges that they defrauded five publicly owned treatment works of nearly $1.28 million by illegally

dumping thousands of loads of waste.

The government charged that a large waste hauling firm illegally dumped some 4,591 loads of waste containing

wastewater treatment sludge or grease on 1,577 different days. The company said it had immediately launched

an investigation upon discovery of the illegal actions, fired the responsible employees, and made a $1.6 million

settlement to one of the cities.

Charges included Clean Water Act violations and mail fraud. The charges carry a maximum penalty of five

years probation and a fine of $50,000 per day for each day of violation. Had the firm correctly reported the

illegal loads, they would have had to pay the numerous POTWs it discharged to approximately $1.28 million.

The company claimed it had settled the case, agreeing to plead guilty to three charges involving mail fraud and

conspiracy, and pay a $3 million fine with an additional $1.5 million toward environmental restoration projects.

Source: The Associated Press – Lubbock Avalanche Journal, November 22, 1996

• Periodic sampling of suspected sewer lines

• Surveillance of waste haulers and suspected discharge points

• Education of industries concerning the seriousness of these violations

• Increased public awareness of illegal dumping

• Increased enforcement.

Many states have enforcement programs to assist POTWs in detecting illegal dischargers.

Federal [EPA’s Criminal Investigation Division (CID) or the FBI] or local law enforcement

officials can also be requested to assist in surveillance activities and enforcement. Video

surveillance of suspected manholes or storm drains is also a possible option. Some POTWs use

locking manholes to discourage illegal dumping at suspected sites.

3.3 Communication

3.3.1 Communication with Other POTWs

To effectively control hauled waste, all POTWs within a geographic region should readily

share the information they receive on hauled waste with each other. When a POTW rejects a

load, the operator should consider contacting nearby facilities where the waste may be delivered,

and inform them why the load was rejected. If a waste load is rejected, the POTW could also
3-21

request the hauler to provide information on when and where the rejected load was discharged. 

POTWs should also communicate with one another to identify frequent violators. A list of

haulers with frequent violations, including type of violation, can be distributed among regional

POTWs.

3.3.2 Communication with Waste Haulers

POTW operators can establish a mailing list of all local waste haulers and provide them

with periodic information on changes in plant policy, reminders of existing plant policies that are

frequently abused, and changes in operating times and fees. POTWs are frequently the only

source of regulatory information for waste haulers.

3.4 Review and Update Controls

After control measures are implemented, they should be periodically reviewed for their

effectiveness and updated as necessary. Additionally, if the type or amount of hauled waste

received changes, the controls should be reviewed to determine if additional controls are needed. 

For example, if a POTW has been receiving only domestic hauled waste and has implemented

procedures to control the discharge of that waste, the introduction of hauled non-domestic waste

may require the implementation of additional controls (e.g., increased monitoring).
4-1

L-E WWTP has a better understanding of the volume

and content of the hauled waste it receives and has

suffered no disruptions since the inception of its waste

hauler program in November of 1996.

Littleton-Englewood WWTP

Waste Hauler Control Program

' Informational mailing

 ' Electronic Cards

 ' Restricted Hours

 ' Sampling Program

' Two Discharge Standpipes

 ' Automatic Locking Gates

 ' Informational Signs

 ' Open Communication with

 Regional POTWs and Haulers

4. CASE STUDIES

The following case studies present some active controls and communication methods used

by larger POTWs with pretreatment programs. Smaller POTWs and non-pretreatment POTWs

can choose controls based on factors such as treatment plant capacity, flows and pollutant

loadings, sensitivity of plant processes, types and amounts of hauled waste accepted, funding, and

local issues and requirements. A POTW should tailor its program to address these factors.

4.1 Littleton-Englewood Colorado

Summary of Waste Hauler Program

The Littleton-Englewood wastewater

treatment plant (L-E WWTP), situated south of

Denver, Colorado, has a treatment capacity of

approximately 26 MGD. As part of an

expansion project for tertiary treatment, the facility upgraded its hauled waste program including 

structural and programmatic levels. The facility allows only domestic hauled waste to be

discharged. Highlights of the POTW’s upgraded hauled waste program are presented below.

Changes were initiated with a large

informational mailing to all area waste

haulers. To help alleviate revenue collection

problems, all haulers were required to furnish

bonds. A minimum $1,000 bond was set for

small haulers. Bonds for haulers with tainted

payment histories were set higher. Large

hauling firms were required to furnish a bond

equaling 2 month’s business with the plant. 

Bonding has been one of the most beneficial changes Littleton-Englewood has made. The plant

has found that problems surrounding the collection of payments have been drastically reduced.
4-2

The POTW issues electronic cards to each hauler vehicle that has satisfied the POTW

bond requirements. The cards streamline the billing process and track who was discharging at a

particular time, reducing manpower needs at the discharge location. Each card provides

information on the owner of the truck and the truck’s capacity. Each truck is charged for its full

capacity, regardless of the actual volume of waste in the truck. Therefore, Littleton-Englewood

avoided purchasing an expensive scale, or allowing the volume of the delivered waste to be

determined by the haulers. The card entry system also allows the facility to trace any loads which

upset the facility to a particular hauler. Haulers are also required to submit a generator sheet at

the time of discharge, indicating the source of the waste. The facility’s hours for hauled waste

discharge are 7:00 am to 7:00 pm weekdays, and 7:00 am to 3:00 pm on weekends.

This new hauled waste discharge program has resulted in the loss of some waste hauler

customers. However, the POTW recovered the costs of accepting hauled wastes for the first time

and has a better understanding of the content of the hauled waste it receives.

Littleton-Englewood also revised their sampling program. The POTW randomly chooses

one day a month for sampling and samples every truck during that day. Of those samples, one is

brought to the onsite lab for analysis of metals, oil and grease, and pH. If a truck refuses to allow

a sample to be taken, its discharge privileges are revoked. The random sampling program has

kept haulers alert, the plant has suffered no disruptions from hauled waste since the new program

began in November of 1996.

Physical modifications to the facility included the installation of two discharge standpipes. 

Waste flows directly from the discharge points to the plant headworks. Some modifications were

also made to allow gravity-feed trucks to discharge more easily. To capture polluted runoff, the

parking stalls are sloped to a drain that empties into the plant headworks. Automatic locking

gates were installed at the entrance and informational signs were placed in plain view of the

haulers.

Littleton-Englewood stays in close contact with neighboring POTWs. The exchange of

information discourages unscrupulous haulers from hauling waste that potentially causes problems
4-3

MSD’s Waste Hauler Control Program

' Permit Application

 ' Transporter and Vehicle ID Number

 ' Designated Discharge Point

 ' Restricted Hours and Access

 ' Manifest Forms

 ' Sampling

 ' Gate and Intercom System

to other facilities. Littleton-Englewood also stays in touch with its waste haulers. Letters are

often mailed and phone calls are made to haulers to explain changes in policy and operating hours,

as well as to provide reminders of facility requirements.

For more information contact: Mary Gardner at (303) 762-2605 or

mgardner@ci-englewood.co.us.

4.2 Metropolitan St. Louis Sewer District (MSD)

Summary of Waste Hauler Program

Background

Metropolitan St. Louis Sewer District (MSD), an independent public agency responsible

for sewers, sewage treatment, and the drainage of rainwater from St. Louis City and St. Louis

County , maintains a $6.5 billion network of pipes, drainage canals, and 8 WWTPs. Only the

largest of these plants, the Bissell Point plant (143 MGD), is designated to receive hauled waste. 

To control such discharges, MSD enforces the provisions of local Ordinance #10082 (see

Appendix G).

All haulers seeking to haul and

discharge waste to MSD's Bissell Point plant

must first apply and obtain approval from

MSD. In addition to providing basic

information such as company name, address,

name and title of Chief Executive Officer,

business activities conducted, and a list of

transport vehicles (including make, model, tank volume, vehicle license information), the applicant

must also detail the types and estimated volumes of waste to be transported and discharged, its

operational service area(s), proof of insurance coverage including comprehensive general liability

and auto liability which includes the POTW as an additional insured party, and certification and

signature of a company official.
4

 MSD defines domestic hauled waste as grease and other food preparation wastes from

restaurants, institutional kitchens, employee cafeterias, and similar meal serving facilities, septage, sanitary

wastewater from sewer line or lift station overflows, sludge from wastewater treatment plants receiving

primarily domestic wastes, and wastes from car washes where only washing of the car body occurs.

4-4

Upon approval of the application, MSD assigns a unique transporter identification number

to the company and assigns permanent decals with unique vehicle identification numbers to each

of the hauler vehicles. These identification numbers and all application information is entered into

the pretreatment database system.

The Bissell Point waste receiving station consists of 4 “pull-through-bays” and 5 manholes

for discharge. The receiving station can accommodate 4-8 trucks at one time, depending on truck

size. Hours of operation are restricted to 7:00 AM and 5:30 PM, Monday thru Friday, excluding

holidays, and 7:00 AM and 12:00 noon on Saturday. During operational hours, MSD personnel

man the receiving station at all times.

Access to the receiving station varies based on the type of waste proposed to be

discharged. Discharge of domestic waste4 merely requires the hauler accurately completing a

carbon M-form. Discharge of waste from an industrial source requires completion of a double

carbon S-form ( the double carbon allows the source to retain a copy of the form prior to the

hauler leaving the source's premises). S-form waste requires the source to complete an

application for special discharge and obtain approval from MSD prior to discharge at the station. 

Where approval is denied, the applicant is required to inform MSD as to where the waste is finally

disposed.
4-5

Upon arrival at the station, the hauler provides the MSD attendant with the appropriate

form based on the nature of the waste hauled. The attendant verifies that the proper form is

completed and verifies that the vehicle identification information corresponds to the vehicle

awaiting to discharge. Deficiencies may be easily resolved by the hauler providing any additional

information needed. Discrepancies, however, may require the MSD attendant to contact waste

sources indicated on the form. Where written pre-approval does not accompany the S-form, the

attendant may access the pretreatment database system to obtain the approval status and to 

disallow a discharge where approval has not yet been authorized.

Every load intended for discharge, regardless of whether the load is accepted, is recorded

by the attendant on a daily receipt log sheet. Information recorded includes date, time and

receipt information. Entry lines of this log sheet are pre-numbered, prompting the attendant to

record this unique number on the appropriate S- or M-form.

Upon satisfactory completion of the required paperwork, a hauler is directed into one of

the discharge bays for sample collection for analyses such as pH, conductivity, appearance, and

odor. The sample is collected with a tanker discharge hose, tank sample spigot, and/or by

accessing the waste through the top hatch. When the attendant (and supervisor if consulted)

believes the waste to be that described on the S- or M-form, the hauler may commence discharge;

otherwise, the load is refused. When the attendant observes a discharge in progress that suddenly

changes appearance, odor, etc., the attendant may halt the discharge and collect an additional

sample(s) for screening, potentially forbidding any continuation of the discharge.

All samples are retained as “verification” samples. Of the verification samples collected

daily, S-form waste and a percentage of M-form waste are selected for full verification analyses. 

This enables MSD to verify that industrial waste (S-form) was that approved for discharge, to

maintain a database of domestic waste characteristics, and potentially to detect the illegal

discharge of industrial waste in an M-form discharge. Verification samples not analyzed are

retained for a period of time so samples can be analyzed in the event of plant upset or operational

problems.
4-6

Receipt data are entered into the pretreatment database and are recorded manually on

monthly summary log sheets. The entered database data is queried monthly to provide the MSD

finance department with an electronic invoice of hauler data for billing purposes. Typically, a

hauler can expect to receive an invoice detailing the date, time, vehicle ID number, vehicle

volume, and amount due, within 10 days of the end of a month.

MSD intends to upgrade the receiving station to provide for additional security and data

tracking measures. Installation of a gate and intercom system will enable MSD attendants to

restrict vehicle entry until they have been able to verify that the vehicle is authorized to enter the

facility, and then keying in the vehicle ID number to open the gate. The camera will operate each

time the gate opens as an independent record of each vehicle entering the facility.

4.3 City of Fayetteville, North Carolina

Summary of Waste Hauler Program

The Public Works Commission (PWC), City of Fayetteville, North Carolina operates two

WWTPs designed to treat a total of 36 MGD of wastewater. The Cross Creek Water

Reclamation Facility (CCWRF), is designated to receive hauled domestic and industrial waste.
4-7

Excerpts from Approval Letter

' John Hauler is authorized to discharge only

residential septage directly from the service

trucks and without prior pretreatment. Grease

trap wastes or commercial or industrial wastes

will not be accepted without separate and prior

authorization. The discharge of wastewater must

be in compliance with Sections 31–44 and

31–46 of the City of Fayetteville Sewer Use

Ordinance.

' It shall be necessary for the truck drivers to use

the proper access card each time waste is

discharged from the truck(s) at the septage

receiving station. Each load will be sampled and

each sample bottle will be properly labeled with

the PWC supplied labels.

' High strength wastes and wastes requiring

special handling may justify an additional fee for

each truckload discharged to the CCWRF. 

Additional fees shall be levied at the prevailing

rate.

' The area surrounding the point of discharge shall

be kept clean at all times. Each driver shall be

responsible for washing down the discharge area

with water prior to departure from the POTW.

' Residential septage may be discharged at

the POTW from dawn to dusk. Any other

arrangement must receive prior authorization

from PWC.

' A copy of this authorization letter must be

maintained in the authorized vehicle discharging

to the POTW. The PWC may require proof of

authorization to discharge prior to any discharge

by any vehicle.

Haulers seeking to transport and

discharge portable toilet waste and/or septic

tank waste must obtain a permit from the health

department and an approval letter from PWC.

PWC issues an access card to each “approved”

hauler vehicle. Such cards contain electronic

data (i.e., company name, approval number,

truck make and model, and truck tank capacity)

allowing the hauler to gain access to CCWRF

and allowing PWC to track haulers entering

CCWRF.

The discharge location for the hauled

waste depends on the nature of the waste and

the size of the truck. Haulers of portable

toilet waste are required to discharge at the

headworks of the plant. Due to the high

solids content of the waste hauled,

transporters of septic tank waste are required

to discharge at a different plant location that

drains directly to CCWRF digesters. Weight

restrictions on the paths/roads leading to these

two discharge locations require heavier

vehicles (e.g., those capable of transporting

>5000 gallons) to discharge to yet a different

location that drains to the headworks of the plant. The first two discharge locations are equipped

with hoses for clean-up by the haulers upon completion of their discharge.

All haulers are required to self-sample the waste discharged. A container, provided by

PWC, is used by the hauler to collect a grab sample from the actively flowing discharge. The
4-8

sample is then provided to PWC for analysis prior to leaving the plant. It is at the discretion of

PWC to conduct analyses on samples provided.

Haulers seeking to transport and discharge industrial waste must obtain a permit from

PWC prior to any discharge. While considered non-SIU permits, these documents contain

requirements and conditions similar to those imposed on PWC SIUs. Since hauled industrial

waste is general transported in large tanker trucks, hauled industrial waste is discharged at the

location that drains to the headworks of the plant. Wastes containing primarily oils and grease

may be accepted at the septic tank discharge location, provided the oil/grease waste is mixed with

septic tank waste prior to discharge to avoid fouling CCWRF equipment and plumbing.

For more information contact: Monica Hayes at (910) 223-4699 or

MWHayesPWC@aol.com.
APPENDIX A

GLOSSARY OF TERMS
A-1

GLOSSARY OF TERMS

Approval Authority: The Director in an NPDES State with an approved State pretreatment program and

the appropriate EPA Regional Administrator in a non-NPDES State or NPDES State without an approved

State pretreatment program. [40 CFR 403.3(c)]

Approved POTW Pretreatment Program: A program administered by a POTW that meets the criteria

established in 40 CFR 403.8 and 403.9 and which has been approved by a Regional Administrator or State

Director in accordance with 40 CFR 403.11. [40 CFR 403.3(d)]

Catchment: A structure, such as a basin, for collecting or draining water.

Categorical Pretreatment Standards: Limitations on pollutant discharges to POTWs promulgated by

EPA in accordance with Section 307 of the Clean Water Act, that apply to specific process wastewater

discharges of particular industrial categories [40 CFR § 403.6 and 40 CFR Parts 405-471].

Clean Water Act (CWA): An act passed by the U.S. Congress to control water pollution. It was formerly

referred to as the Federal Water Pollution Control Act of 1972 or Federal Water Pollution Control Act

Amendments of 1972 (Public Law 92-500), 33 U.S.C. 1251 et. Seq., as amended by : Public Law 96-483:

Public Law 97-117; Public Laws 95-217, 97-117, 97-440 and 100-04. 

Composite Sample: Sample composed of two or more discrete samples. The aggregate sample will reflect

the average water quality covering the compositing or sample period.

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA): This act was

passed in 1980 and is commonly known as “Superfund”. CERCLA gives the Federal government the

power to respond to releases, or threatened releases, of any hazardous substance into the environment as

well as to a release of a pollutant or contaminant that may present an imminent and substantial danger to

public health or welfare. 

Control Authority: A POTW with an approved pretreatment program or the approval authority (State or

EPA Region) in the absence of a POTW pretreatment program [40 CFR § 403.12(a)].
A-2

Domestic Septage: The liquid or solid material removed from a septic tank, cesspool, holding tank, or

similar system that receives only domestic waste (household, non-commercial, non-industrial sewage).

Facility Operator: Person or persons possessing day-to-day control over the operations at a Publicly

Owned Treatment Works.

Grab Sample: A sample which is taken from a wastestream without regard to the flow in the wastestream

and over a period of time not to exceed fifteen (15) minutes.

Hauled Wastes: Any wastes delivered by truck or rail car.

Hazardous Waste: As defined in RCRA: a solid waste, or combination of solid wastes, which because of

its quantity, concentration, or physical, chemical, or infectious characteristics may -

a) cause, or significantly contribute to an increase in mortality or an increase in serious irreversible,

or incapacitating reversible, illness; or

b) pose a substantial present or potential hazard to human health or the environment when improperly

treated, stored, transported, or disposed of, or otherwise managed.

As defined in the regulations, a solid waste is hazardous if it meets one of four conditions:

1) Exhibits a characteristic of a hazardous waste (40 CFR Sections 261.20 though 262.24)

2) Has been listed as hazardous (40 CFR Sections 261.31 through 261.33)

3) Is a mixture containing a listed hazardous waste and a nonhazardous solid waste (unless the

mixture is specifically excluded or no longer exhibits any of the characteristics of hazardous waste)

4) Is not excluded from regulation as a hazardous waste.

Homogeneous: Uniform in structure or composition throughout.

Indirect Discharge: The introduction of pollutants into a POTW from any non-domestic source regulated

under Section 307(b), (c), or (d) of the Act. [40 CFR 403.3(g)]

Industrial User: A source of indirect discharge. [40 CFR 403.3(h)]
A-3

Interference: A discharge, which alone or in conjunction with a discharge or discharges from other

sources, inhibits or disrupts the POTW, its treatment processes or operations or its sludge

processes, use or disposal; and therefore, is a cause of a violation of the POTW’s NPDES permit or of the

prevention of sewage sludge use or disposal in compliance with any of the following statutory/regulatory

provisions or permits issued thereunder, or any more stringent State or local regulations: Section 405 of the

CWA; the Solid Waste Disposal Act, including Title II commonly referred to as the Resource Conservation

and Recovery Act (RCRA); any State regulations contained in any State sludge management plan prepared

pursuant to Subtitle D of the Solid Waste Disposal Act; the Clean Air Act; the Toxics Substances Control

Act; and the Marine Protection, Research, and Sanctuaries Act. [40 CFR 403.3(I)]

Local Limits: Discharge limits imposed by municipalities upon industrial or commercial users that

discharge to the municipal sewage treatment system.

National Pretreatment Standard or Pretreatment Standard: Any regulation containing pollutant

discharge limits promulgated by EPA in accordance with Section 307(b) and (c) of the Clean Water Act,

that apply to industrial users. This term also includes the prohibited discharge standards under 40 CFR §

403.5. [40 CFR 403.3(j)]

Non-pretreatment POTWs: POTWs not subject to the National Pretreatment Program or POTWs

without approved pretreatment programs.

Pass Through: A discharge which exits the POTW into waters of the United States in quantities or

concentrations which, alone or in conjunction with a discharge or discharges from other sources, is a cause

of a violation of any requirement of the POTW’s NPDES permit, including an increase in the magnitude or

duration of a violation. [40 CFR 403.3(n)]

Pathogen: a microorganism, such as a bacterium or fungus, that causes disease.

pH - A measure of the acidity or alkalinity of a solution, expressed in standard units

Pretreatment: the reduction of the amount of pollutants, the elimination of pollutants, or the alteration of

the nature of pollutant properties in wastewater prior to or in lieu of discharging or otherwise introducing

such pollutants to a POTW. [40 CFR 403.3(q)].
A-4

Prohibited Discharge Standards: Prohibitions on the discharge of certain substances, as defined in 40

CFR 403.5.

Publicly Owned Treatment Works (POTW): Any device or system used in the treatment (including

recycling and reclamation) of municipal sewage or industrial wastes of a liquid nature which is owned by a

State or municipality. This includes sewers, pipes or other conveyances only if they convey wastewater to

a POTW providing treatment.

Sludge (Biosolids): The solid, semi-solid, or liquid residue generated during the treatment of wastewater. 

Slug load: Any discharge of a non-routine, episodic nature, including but not limited to, an accidental spill

or a noncustomary batch discharge. [40 CFR 403.8(f)(2)(v)]

Time Proportional Sample: A sample consisting of a series of aliquots collected from a representative

point in the discharge stream at equal times intervals over the entire discharge period on the sampling day.

Toxic Pollutant: Any pollutant listed as toxic under section 307(a)(1) of the CWA, or in the case of

sludge use or disposal practices, any pollutant identified in regulations implementing section 405(d) of the

CWA.

Wastewater: The used water and water-carried solids from a community (including domestic,

commercial, and industrial sources) that flow to a treatment plant. Storm water, surface water, and

groundwater infiltration also may be included in the wastewater that enters a wastewater treatment plant.
APPENDIX B

BIBLIOGRAPHY

B-1

BIBLIOGRAPHY

Henry, Glynn and Durga Prasad. Anaerobic Treatment of Leachate. Paper presented at seminar on

leachate treatment and disposal, sponsored by the Pollution Control Association of Ontario and the Ontario

Ministry of Environment. Toronto, Ontario, 1991. As cited in Guidelines for Environmental Monitoring

at Municipal Solid Waste Landfills. Municipal Waste Reduction Branch of the British Columbia Ministry

of Environment, Lands and Parks. January 1996.

Lu, James C.S., Bert Eichenberger, and Robert J. Sterns. Leachate from Municipal Landfills: Production

and Management. Noyes Publications. 1985. As cited in Guidelines for Environmental Monitoring at

Municipal Solid Waste Landfills. Municipal Waste Reduction Branch of the British Columbia Ministry of

Environment, Lands and Parks. January 1996.

U.S. EPA RCRA Information on Hazardous Wastes for Publicly Owned Treatment Works.

September 1985 (EPA/530-SW-86-001)

U.S. EPA Domestic Septage Regulatory Guidance, A Guide to the EPA 503 Rule. September 1993

(EPA832-0-92-005)

U.S. EPA Control of Slug Loadings to POTWs. February 1991(21W-4001)

U.S. EPA Guidance Manual on the Development and Implementation of Local Discharge Limitations

Under the Pretreatment Program. December, 1987 (833-B-87-202)

U.S. EPA RCRA Information on Hazardous Wastes for Publicly Owned Treatment Works. September

1985 (833-B-85-202)

U.S. EPA Guidance Manual for the Identification of Hazardous Wastes to Publicly Owned Treatment

Works by Truck, Rail, or Dedicated Pipeline. June 1987

U.S. EPA CERCLA Site Discharges to POTWs. August 1990 (EPA/542/6-90/005)
B-2

U.S. EPA Guide to Septage Treatment and Disposal. September 1994 (EPA/625/R-94/002)

U.S. EPA Supplemental Manual on the Development and Implementation of Local Discharge

Limitations Under the Pretreatment Program. May 1991 (21W-4002)

U.S. EPA. Industrial User Permitting Guidance Manual. September 1989.

Thompson, Vanessa and Denow, Ken The Effects of the Pretreatment Program on Hauled Waste in

Wisconsin, Wisconsin Department of Natural Resources, May 5, 1997
APPENDIX C

LIST OF STATE AND REGIONAL PRETREATMENT COORDINATORS

C-1

PRETREATMENT COORDINATORS

Region I

Justin (Jay) Pimpare

U.S. EPA - Region 1

J.F.K. Federal Building / CMU

One Congress Street

Boston, MA 02114

(617) 918-1531

FAX (617) 918-2064

pimpare.justin@epa.gov

Enforcement Contact: Joe Canzano (617) 918-1763

canzano.joseph@epa.gov

Mr. Mike Harder, Director

Engineering and Enforcement

Department of Environmental Protection

Bureau of Water Management

79 Elm St

Hartford, CT 06106-5127

(860) 424-3701

Mr. Jim Grier, Pretreatment Coordinator

Department of Environmental Protection

Bureau of Water Management

79 Elm St.

Hartford, CT 06106-5127

(860) 424-3839

Mr. Brian Kooiker, Chief

Direct Discharge Section

Vermont Dept. of Environ. Conservation

Permits, Compliance & Protection Division

The Annex Building

103 South Main Street

Waterbury, VT 05676

(802) 241-3822

 brian.kooiker@anrmail.anr.state.vt.us

Mr. George F. Carlson, Jr.*

Surface Water Quality Bureau

NH Department of Environmental Services

P.O. Box 95

6 Hazen Drive

Concord, NH 03302-0095

(603) 271-2052; FAX (603) 271-7894

g_carlson@des.state.nh.us

Mr. Bob DiSaia, Supervising Engineer

Permits, Pretreatment & Planning Section

RI Dept. of Environmental Management

Water Resources Division

235 Promenade Street

Providence, RI 02908

(401) 222-6519; FAX (401) 521-4230

Rdisaia@dem.state.ri.us

Mr. Jim Rogers,*

Environmental Specialist

Division of Water Resource Regulations

ME Department of Environmental Protection

Land & Water Quality Bureau

Statehouse Station 17

Augusta, ME 04333

(207) 287-7774; FAX (207) 287-7191

jim.r.rogers@state.me.us

* State Program not approved; EPA is approval authority
C-2

Region II

Virginia Wong

U.S. EPA - Region 2

Water Compliance Branch 

290 Broadway - 20th Floor 

New York, NY 10007-1866

(212) 637-4241

FAX (212) 637-4211

wong.virginia@epa.gov

Other Contact: Phil Sweeney (212) 637-3873

Jacqueline Rios (212) 637-3859

Ms. Mary Jo Aiello,

Bureau Chief (CN-029)

Bureau of Pretreatment and Residuals

NJ Dept. of Env. Protection

401 E. State Street, 4th Floor

Trenton, NJ 08625

(609) 633-3823

maiello@dep.state.nj.us

Jim Murphy,

Principal Environmental Engineer 

NJ Dept. of Env. Protection

401 E. State Street, 4th Floor

Trenton, NJ 08625

(609) 633-3823

jmurphy@dep.state.nj.us

Ms. Wanda Garcia,*

Permits Section Chief

Environmental Quality Board

Commonwealth of Puerto Rico

P.O. Box 11488

Santurce, PR 00910

(787) 751-1891

Mr. Robert Cronin, Director*

Bureau of Watershed Compliance Programs

NYS Dept. of Environmental Conservation

50 Wolf Road

Albany, NY 12233-3506

(518) 457-5968; FAX (518) 457-7038

Richard M Cukrovany, P.E.

Bureau of Watershed Compliance Programs

NYS Dept of Environmental Conservation

50 Wolf Rd.

Albany, NY 12233-3506

(518) 457-5968; FAX (518) 457-7038

Mr. Ben Nizario, Director *

Environmental Protection Division

VI Department of Natural Resources

Nisky Center, Suite 231

North 45A Estate Nisky

Charlotte Amalie

St. Thomas, VI 00802

(809) 774-3320
C-3

Region III

John Lovell

U.S. EPA - Region 3

Office of Municipal Assistance (3WP24)

1650 Arch Street

Philadelphia, PA 19103-2029

(215) 814-5790

FAX (215) 814-2302

lovell.john@epa.gov

Other Contact: Steve Copeland (215) 814-5792

Mr. James Collier, Chief*

Water Hygiene Branch

D.C. Dept of Consumer & Regulatory Affairs

2100 Martin Luther King Ave., SE

Suite 203

Washington, DC 20020

(202) 404-1120

Mr. Gary F. Kelman, Head - Pretreatment Section

Maryland Dept of the Environment

Industrial Discharge Permits Division

Water Management Administration

2500 Broening Highway

Baltimore, MD 21224

(410) 631-3630; FAX (410) 631-3163

gkelman@mde.state.md.us

Mr. Joe Mulrooney *

Delaware Dept. of Natural Resources &

Environmental Control

Division of Water Resources

Pollution Control Branch

89 Kings Highway

Dover, DE 19901

(302) 739-5731

Mr. R.B. Patel, Chief,* Permits Section

PA Department of Env. Resources

Bureau of Water Quality Management

P.O. Box 2063

Harrisburg, PA 17120

(717) 787-8184; FAX (717) 772-5156

patel.ratilal@a1.dep.state.pa.us

Mr. Burton R. Tuxford,

Pretreatment Coordinator

VA Dept. of Environmental Quality

Office of Water Permit Support

629 E. Main Street; PO Box 10009

Richmond, VA 23240

(804) 698-4086; FAX (804) 698-4500

brtuxford@deq.state.va.us

Mr. David Montali, Pretreatment Coordinator

Water Resources Section

WV Dept. of Commerce, Labor & Environmental

Resources

Division of Natural Resources

1201 Greenbrier Street

Charleston, WV 25311

(304) 558-4086; FAX (304) 558-5903

dmontali@mail.dep.state.wv.us
C-4

Region IV

Melinda Mallard Greene

U.S. EPA - Region 4 (AFC/16th Floor)

Water Permits & Enforcement Branch

61 Forsyth Street

Atlanta, GA 30303-3415

(404) 562-9771

FAX (404) 562-9728

mallard.melinda@epa.gov

Mr. Robert E. Heilman

Domestic Wastewater Section (MS #3540)

FL Department of Environmental Protection

Twin Towers Office Building

2600 Blair Stone Road

Tallahassee, FL 32399-2400

(850) 488-4524; FAX (850) 921-6385

robert.heilman@dep.state.fl.us

Mr. Ed Hughs

Pretreatment Coordinator, Water Division

Alabama Dept. of Environ. Management

1751 Cong. WL Dickinson Drive

Montgomery, AL 36130

334-271-7838; FAX 334-279-7950

ekh@adem.state.al.us

Mr. Jim Sommerville, Manager

Municipal Permitting

Georgia Dept. of Natural Resources

Environmental Protection Division

Atlanta Tradeport, Suite 110

4244 International Parkway

Atlanta, GA 30354

(404) 362-2680; FAX (404) 362-2691 

jim_sommerville@mail.dnr.state.ga.us

Mr. Harry M. Wilson III, P.E.

Pretreatment Program

Office of Pollution Control

MS Dept. of Environmental Quality

P.O. Box 10385

Jackson, MS 39209-0385

(601) 961-5122; FAX (601) 961-5703

harry_wilson@deq.state.ms.us

Ms. Sandra Gruzesky, Pretreatment Section

Kentucky Dept. of Environmental Protection

Division of Water/KPDES Branch

14 Reilly Road, Frankfort Office Park

Frankfort, KY 40601-1189

(502) 564-2225 ext 459; FAX (502) 564-3949

gruzesky@nrdep.nr.state.ky.us

Mr. Abe Rowson, Pretreatment Coordinator

SC Dept. of Health & Environmental Control

2600 Bull Street

Columbia, SC 29201-1706

(803) 898-4160; FAX (803) 898-4215

rowsonae@columb32.dhec.state.sc.us

Mr. Tom S. Poe

Division of Water Quality

NC Dept. of Natural Resources and Community

Development

P.O. Box 29535

Raleigh, NC 27626-0535

(919) 733-5083 ext 522; FAX (919) 715-6048

tom_poe@h2o.enr.state.nc.us

Mr. Anthony James, Manager Wastewater

Management Section

SC Dept. of Health & Environmental Control 

2600 Bull Street

Columbia, SC 29201-1706

(803) 734-5268

 Mr. Chuck Durham

TN Division of Water Pollution Control

6th Floor, L & C Annex

401 Church Street

Nashville, TN 37243-1534

(615) 532-0638; FAX (615) 532-0614

cdurham@mail.state.tn.us
C-5

Region V

Matthew Gluckman

Pretreatment Coordinator

U.S. EPA - Region 5

NPDES Support & Technical Assistance Branch (WN-16J)

77 West Jackson Blvd.

Chicago, IL 60604-3507

(312) 886-6089

FAX (312) 886-7804

gluckman.matthew@epa.gov

Other Contact: Cathy Scudieri (312) 353-2098

Pretreatment Enforcement Manager - Carol Staniec (312) 886-1436

Ms. Jennie Leshnock

State Pretreatment Coordinator

Ohio Environmental Protection Agency

P.O. Box 1049

1800 Water Mark Drive

Columbus, OH 43266-1049

(614) 644-2028

jennie.leshnock@epa.state.oh.us

Mohammed Islam

mohammed.islam@epa.state.oh.us

Mr. Steve Nightengale*

Division of Water Pollution Control

IL Environmental Protection Agency

2200 Churchill Road

P.O. Box 19276

Springfield, IL 96792-9272

(217) 782-0610

Mr. Kevin Cohoon

IN Dept. of Environmental Management

105 South Meridian St

PO Box 6015

Indianapolis, IN 46206-6015

(317) 233-0570

kchoon@dem.state.in.us

Mr. Chuck Schuler, 

Pretreatment Coordinator

Wisconsin Department of Natural Resources

Watershed Management, WT/2

P.O. Box 7921

Madison, WI 53707

(608) 267-7631

schulc@dnr.state.wi.us

Mr. Bill Blue,* Pretreatment Coordinator

IN Dept. of Environmental Management

105 South Meridian St.

P.O. Box 6015

Indianapolis, IN 46206-6015

(317) 232-8729

bblue@dem.state.in.us

Ms. Grace Scott

Michigan Dept. of Environmental Quality

Knapps Center, 2nd Floor

300 Washtenaw Street

P.O. Box 30028

Lansing, MI 48933

(517) 373-8566

scottg@deq.state.mi.us
C-6

Ms. Jodi Lynn Peace

Environmental Quality Analyst 

SE Michigan Dist HQ

38980 West 7 Mile Road

Livonia, MI 48152

(734) 953-1433; FAX (734) 953-1467

peacej@state.mi.us

Ms. Nanette E. Jameson

Pretreatment Coordinator/Wastewater Spec.

NE Region HQ

Wisconsin Department of Natural Resources

1125 N. Military Ave; Box 10448

Green Bay, WI 54307-0448

(920) 492-5874; FAX (920) 492-5913

jamesn@dnr.state.wi.us

Mr. Randy Dunnette

Pretreatment Coordinator

Minnesota Pollution Control Agency

520 Lafayette Road

St. Paul, MN 55155-4194

(651) 296-8006

randall.dunnette@pca.state.mn.us
C-7

Region VI

Lee Bohme

U.S. EPA - Region 6

NPDES Permits Branch (6WQ-PO)

Fountain Place, 12th Floor, Suite 1200

1445 Ross Avenue

Dallas, TX 75202-2733

(214) 665-7532

FAX (214) 665-2191 / (214) 665-6490

bohme.lee@epa.gov

Other Contacts: Mike Tillman (214) 665-7531

Enforcement Contact: Bob Goodfellow (214) 665-6632

Mr. Allen Gilliam, Pretreatment Coordinator

Arkansas Dept. of Pollution Control & Ecology

P.O. Box 8913

8001 National Drive

Little Rock, AR 72219-8913

(501) 682-0625; FAX (501) 682-0910

gilliam@adeq.state.ar.us

Mr. Steve Bumgarn,* 

Water Resources Specialist 

Surface Water Quality Bureau

New Mexico Dept. of the Environment

1190 Saint Francis Drive, Room N-2050

Santa Fe, NM 87502

(505) 827-2823; FAX (505) 827-0160

Ms. Jill Russell, Pretreatment Team Leader

Water Quality Division

Texas Natural Resource Conservation Commission

P.O. Box 13087, Capitol Station

Austin, TX 78711-3087

(512) 239-4564; FAX (512) 239-4430

jrussell@tnrcc.state.tx.us

Ms. Rebecca Villalba

(512) 239-4784; FAX (512) 239-4430

rvillalb@tnrcc.state.tx.us

Mr. Patrick King

Pretreatment Coordinator

Water Quality Service

Oklahoma Dept. of Environmental Quality

P. O. Box 1677

Oklahoma City, OK 73101-1677

(405) 702-8193; FAX (405) 702-8101

patrick.king@deqmail.state.ok.us

Mr. Ronnie Bean, Pretreatment Coordinator

Water Pollution Control Division

Louisiana Dept. of Environmental Quality

P.O. Box 82215

Baton Rouge, LA 70884-2215

(504) 765-2779; (504) 765-0635

ronnie_b@deq.state.la.us
C-8

Region VII

Paul Marshall, P.E.

U.S. EPA - Region 7

726 Minnesota Avenue

Kansas City, KS 66101

(913) 551-7419

FAX (913) 551-7765

marshall.paul@epa.gov

Other Contact: Mike Turvey (913) 551-7424

Mr. Steve Williams, 

Environmental Specialist

Iowa Department of Natural Resources

Wallace State Office Building

900 East Grand

Des Moines, IA 50319

(515) 281-8884; FAX (515) 281-8895

swillia@max.state.ia.us

Mr. Richard Kuntz, P.E.,

Pretreatment Coordinator

Missouri Department of Natural Resources

P.O. Box 176

205 Jefferson Street

Jefferson City, MO 65102

(573) 751-6996

nrkuntz@mail.dnr.state.mo.us

Mr. Rudy Fiedler, 

Pretreatment Coordinator

NE Department of Environmental Quality

P.O. Box 98922

State Office Building

Suite 400, The Atrium

Lincoln, NE 68509-8922

(402) 471-4209; FAX (402) 471-2909

Mr. Steve Caspers,* 

Pretreatment Specialist

Industrial Programs Section

Kansas Department of Health & Environment

Bureau of Water

Forbes Field, Bldg 283

Topeka, KS 66620-0001

(785) 296-5551; FAX (785) 296-5509
C-9

Region VIII

Curt McCormick

U.S. EPA - Region 8

NPDES Branch (8P-W-P)

999 18th Street, Suite 500

Denver, CO 80202-2466

(303) 312-6377

FAX (303) 312-7084 

mccormick.curt@epa.gov

Other Contact: Bruce Kent (303) 312-6133

kent.bruce@epa.epa.gov

Mr. Joe Strasko,* 

Permits Officer

Montana Department of Health and Environmental

Sciences

Water Quality Bureau

Cogswell Bldg., Room A-206

Helena, MT 59620

(406) 444-2406

Mr. Rick Koplitz, * 

Pretreatment Coordinator

Colorado Department of Health

4300 Cherry Creek Drive South

Denver, CO 80246-1530

(303) 692-3618; FAX (303) 782-0390

rick.koplitz@state.co.us

Mr. Gary Bracht, * 

Chief, Permits Section

North Dakota State Health Department.

P.O. Box 5520

Bismarck, ND 58502-5520

(701) 328-5227

gbracht@ranch.state.nd.us

Ms. Paula Huizenga

Natural Resources Engineer

South Dakota Department of Environment & Natural

Resources

Joe Foss Bldg.

523 E. Capitol

Pierre, SD 57501

(605) 773-3351

paula.huizenga@state.sd.us

Ms. Leah Krafft,* Environmental Senior Analyst

WY Department of Environmental Quality

Water Quality Division 

Herschler Bldg., 4th Floor West

Cheyenne, WY 82002

(307) 777-7093; FAX (307) 777-5973

lkraff@missc.state.wy.us

Ms. Gwen Jacobs

Environmental Protection Specialist

USEPA Region VIII

Montana Operations Office

Federal Building

301 S. Park; Drawer 10096

Helena, MT 59626

(406) 441-1130 x235; FAX (406) 441-1125

jacobs.gwen@epa.gov

Mr. Nathan Guinn,

Pretreatment Coordinator

Utah Department of Environmental Quality

Division of Water Quality

288 North 1460 West

Salt Lake City, UT 84114-4870

(801) 538-6146; FAX (801) 538-6126

nguinn@deq.state.ut.us
C-10

Region IX

Keith Silva

U.S. EPA - Region 9

Clean Water Act Compliance Office (WTR-7)

75 Hawthorne Street

San Francisco, CA 94105

(415) 744-1907

FAX (415) 744-1235

silva.keith@.epa.gov

Mr. Joseph Livak* 

Bureau of Water Pollution Control

NV Division of Environmental Protection

Capital Complex

333 West Nye Lane

Carson City, NV 89710

(702) 687-4670 x3143; FAX (702) 687-5856

Mr. Mark Charles*

Surface Water Enforcement

Office of Water Quality

AZ Department of Environmental Quality

3033 North Central Avenue

Phoenix, AZ 85012-2809

(602) 207-4567; FAX (602) 207-4467

Mr. Denis Lau, Chief

Clean Water Branch

Hawaii Department of Health

P.O. Box 3378

500 Ala Moana Blvd.

Honolulu, HI 96801-3378

(808) 586-4309

dlau@eha.health.state.hi.us

Gordon Innes

California State Water RCB

Division of Water Quality

P.O. Box 100

901 P Street

Sacramento, CA 95814-0100

(916) 657-0775; FAX (916) 657-2388

Mr. James W. Kassel, Chief

Regulation Unit

CA State Water Resources Control Board

Division of Water Quality

P.O. Box 100

901 P Street

Sacramento, CA 95814-0100

(916) 657-0775; FAX (916) 657-2388

kassj@dwq.swrcb.ca.gov
C-11

Region X

Sharon Wilson

U.S. EPA - Region 10

NPDES Permits Unit (OW-130)

1200 Sixth Avenue

Seattle, WA 98101-1128

(206) 553-0325

FAX (206) 553-0165/553-1280

 wilson.sharon@epa.gov

Mr. Chuck Hopkins,

Pretreatment Coordinator

Water Quality Division

OR Department of Environmental Quality

811 SW 6th Avenue

Portland, OR 97204-1390

(503) 229-6528; FAX (503) 229-6037

hopkins.chuck@deq.state.or.us

Doug Knutson

Washington Department of Ecology

Northwest Regional Office, M/S NB-81

3190 - 160th Avenue SE

Bellevue, WA 98008-5452

(425) 649-7025; FAX(425) 649-7098

dknu461@ecy.wa.gov

David J. Knight, Pretreatment Coordinator

Washington Department of Ecology

Southwest Regional Office

P. O. Box 47775

Olympia, WA 98504-7775

(360) 407-6277; FAX (360) 407-6305

dakn461@ecy.wa.gov

Phelps Freeborn

WA Department of Ecology

Central Regional Office

15 West Yakima Ave., Suite 200

Yakima WA 98902

(509) 454-7277; FAX (509) 454-4339

wfre461@ecy.wa.gov

Ken Merrill

WA Department of Ecology

Eastern Regional Office

N. 4601 Monroe Street, Suite 100

Spokane, WA 99205

(509) 456-6148; FAX(509) 456-6175

kmer461@ecy.wa.gov

Mr. Jerry Yoder *

Division of Environmental Quality

Idaho Department of Health and Welfare

State House Mail

1410 North Hilton

Boise, ID 83720-9000

(208) 334-5898
C-12

US EPA HEADQUARTERS CONTACTS

U.S. Environmental Protection Agency

Pretreatment and Multimedia Branch

Permits Division (MC4203)

401 M Street, SW

Washington, DC 20460

FAX (202) 260-1460

Patrick Bradley (202) 260-6963 bradley.patrick@epa.gov

Brian Frazer (202) 260-0101 frazer.brian@epa.gov

John Hopkins (202) 260-9527 hopkins.john@epa.gov

Jan Pickrel (202) 260-7904 pickrel.jan@epa.gov

Jeff Smith (202) 260-5586 smith.jeff@epa.gov
APPENDIX D

WASTE TRANSPORTER AUTHORIZATION APPLICATION

EXAMPLE
Metropolitan St. Louis Sewer District

Waste Transporter Authorization Application

(Please see instructions on the reverse side of this form)

Section A - Company Information

MSD Assigned

1. Company Name: Transporter ID:

2. Mailing Address: 

 ZIP Code: 

3. Name of Contact Person: Telephone: ( )

4. Name and Title of Chief Executive:

5. Premise Address: 

 ZIP Code: 

6. Activities at this premise: 

7. Dispatcher Name: Dispatcher Telephone: ( )

Section B - Waste Transport Vehicles

Vehicle Make Model

Tank

Volume

(gallons

)

Vehicle License Information St. Louis

County

HPN

MSD

Assigned

Vehicle ID

Number

License

No. State ExpirationDate

1

2

3

4

Section C - Waste Information

1. Types and estimated annual volumes of wastes 

 to be transported and discharged to MSD:

2. Areas in which your company 

 will operate:

Industrial Waste St. Louis City

Landfill Leachate St. Louis County, MO

Sludge Jefferson County, MO

Septic Tanks St. Charles County, MO

Portable Toilets Illinois

Grease Traps Other

Other

Section D - Insurance Attach a certificate documenting that your company has adequate comprehensive

general liability and auto liability insurance which includes the District as an additional insured and includes

provisions for informing the District 10 days prior to the time of policy cancellations or renewals.

I have personally examined and am familiar with the information submitted in this document and attachments and

certify the information to be true, accurate, and complete. I further agree to operate under provisions of all

pertinent District Ordinances and realize failure to do so may result in my discharge privileges being revoked and

enforcement action being taken against me.

Name and Title of signing official: 

Signature: Date: 
APPENDIX E

SUMMARY OF INDUSTRIES REGULATED BY CATEGORICAL STANDARDS

AND PROCESS DESCRIPTIONS
Summary of Categorical Pretreatment Standards

Category 40 CFR

Part Subparts Type ofStandard Overview of Pretreatment Standards

Aluminum Forming 467 A-F PSES

PSNS

Limits are production-based, daily maximums and monthly averages. 

Subpart C prohibits discharges from certain operations.

Battery Manufacturing 461 A-G PSES

PSNS

Limits are production-based, daily maximums and monthly averages. 

No discharge is allowed from any process not specifically identified

in the regulations.

Builders' Paper and

Board Mills

431 A PSES

PSNS

Limits are production-based daily maximums. These facilities may

certify they do not use certain compounds in lieu of performing

monitoring to demonstrate compliance.

Carbon Black

Manufacturing

458 A-D PSNS Limits are for Oil & Grease only (no limit duration specified).

Coil Coating 465 A-D PSES

PSNS

Limits are production-based, daily maximums and monthly averages. 

Copper Forming 468 A PSES

PSNS

Limits are production-based, daily maximums and monthly averages.

Electrical and Electronic

Components

469 A-D PSES

PSNS

Limits are concentration-based, daily maximums and 30 day

averages or monthly averages (varies per subpart and pollutant

parameter). Certification is allowed in lieu of monitoring for certain

pollutants when a management plan is approved and implemented.

Electroplating 413 A-B, D-H PSES Limits are concentration-based (or alternative mass-based

equivalents), daily maximums and four consecutive monitoring days

averages. Two sets of limits exist, depending on if facility discharges

more or less than 10,000 gallons per day of process wastewater. 

Certification is allowed in lieu of monitoring for certain pollutants

when a management plan is approved and implemented.

Feedlots 412 B PSNS Discharge of process wastewater is prohibited, except when there is

an overflow resulting from a chronic or catastrophic rainfall event.

Fertilizer Manufacturing 418 A-G PSNS Limits may specify zero discharge of wastewater pollutants (Subpart

A), production-based daily maximums and 30-day averages

(Subparts B-E) or concentration-based (Subparts F-G) with no limit

duration specified.

Glass Manufacturing 426 H, K-M PSNS Limits are either concentration- or production-based, daily maximums

and monthly averages.

Grain Mills 406 A PSNS Discharge of process wastewater is prohibited at a flow rate or mass

loading rate which is excessive over any time period during the peak

load at a POTW.

Ink Formulating 447 A PSNS Regulations specify no discharge of process wastewater pollutants to

the POTW.

Inorganic Chemicals

Manufacturing

415 A-BO PSES

PSNS

Limits vary for each subpart with a majority of the limits

concentration-based, daily maximums and 30-day averages, or may

specify no discharge of wastewater pollutants. Numerous subparts

have no pretreatment standards.

Iron and Steel

Manufacturing

420 A-F, H-J, L PSES

PSNS

Limits are production-based, daily maximums and 30 day averages.

Leather Tanning and

Finishing

425 A-I PSES

PSNS

Limits are concentration-based, daily maximums and monthly

averages. In certain instances, production volume dictates

applicable pretreatment standards.

Metal Finishing 433 A PSES

PSNS

Limits are concentration-based, daily maximums and monthly

averages. Certification is allowed for certain pollutants where a

management plan is approved and implemented.

Metal Molding and

Casting

464 A-D PSES

PSNS

Limits are primarily production-based, daily maximums and monthly

averages. Discharges from certain processes are prohibited

(Subparts A-C).
Category 40 CFR

Part Subparts Type ofStandard Overview of Pretreatment Standards

E-2

Nonferrous Metals

Forming and Metal

Powders

471 A-J PSES

PSNS

Limits are production-based, daily maximums and monthly averages. 

In some instances, the regulations prohibit the discharge of

wastewater pollutants.

Nonferrous Metals

Manufacturing

421 B-AE PSES

PSNS

Limits are production-based, daily maximums and monthly averages. 

The majority of the Subparts have both existing and new source

limits, with others having solely new source requirements.

Organic Chemicals,

Plastics, and Synthetic

Fibers

414 B-H, K PSES

PSNS

Limits are mass-based (concentration-based standards multiplied by

process flow), daily maximums and monthly averages. Standards for

metals and cyanide apply only to metal- or cyanide-bearing

wastestreams.

Paint Formulating 446 A PSNS Regulations specify no discharge of process wastewater pollutants to

the POTW.

Paving and Roofing

Materials (Tars and

Asphalt)

443 A-D PSNS Limits are for Oil & Grease only (no limit duration specified).

Pesticide Chemicals 455 A, C, E PSES

PSNS

Limits are mass-based (concentration-based standards multiplied by

process flow), daily maximums and monthly averages. Subpart C

specifies no discharge of process wastewater pollutants but provides

for pollution prevention alternatives. Subpart E specifies no

discharge of process wastewater pollutants.

Petroleum Refining 419 A-E PSES

PSNS

Limits are concentration-based (or mass based equivalent), daily

maximums.

Pharmaceutical

Manufacturing

439 A-D PSES

PSNS

Limits are concentration-based, daily maximums and monthly

averages. These facilities may certify they do not use or generate

cyanide in lieu of performing monitoring to demonstrate compliance.

Porcelain Enameling 466 A-D PSES

PSNS

Limits are concentration-based (or alternative production-based),

daily maximums and monthly averages. Subpart B prohibits

discharges certain operations.

Pulp, Paper, and

Paperboard

430 A-G, I-L PSES

PSNS

Limits are production-based daily maximums and monthly averages. 

These facilities may certify they do not use certain compounds in lieu

of performing monitoring to demonstrate compliance. Facilities

subject to Subparts B and E must also implement Best Management

Practices as identified.

Rubber Manufacturing 428 E-K PSNS Limits are concentration- or production-based, daily maximums and

monthly averages.

Soap and Detergent

Manufacturing

417 O-R PSNS Regulations specify no discharge of process wastewater pollutants to

the POTW.

Steam Electric Power

Generating

423 N/A PSES

PSNS

Limits are either concentration-based, daily maximums, or

“maximums for any time”, or compliance can be demonstrated

through engineering calculations.

Timber Products

Processing

429 F-H PSES

PSNS

All PSNS (and PSES for Subpart F) prohibit the discharge of

wastewater pollutants. PSES for Subparts G and H are

concentration-based, daily maximums (with production-based

alternatives).
E-3

CATEGORICAL INDUSTRY DESCRIPTION

The following list provides a description of industrial categories that are regulated by National pretreatment standards and the

General Pretreatment Regulations. Numerical discharge standards have been developed for each of the categories listed.

ALUMINUM FORMING (AF)

Aluminum Forming is a physical process by which aluminum or aluminum alloys are changed from their original size and shape

to a desired size and shape. The processes by which such reformation is accomplished are described as rolling, extrusion, forging, and

drawing. An example of aluminum forming is the manufacture of aluminum wire by extrusion. The aluminum or an aluminum alloy is heated

and forced through a small hole (extrusion) changing its form from bulk to long, thin strands.

BATTERY MANUFACTURING (BP)

The Battery Manufacturing category encompasses the process by which a wide variety of consumer and industrial batteries are

produced. This category does not include stores that sell batteries, only facilities that manufacture them.

COIL COATING (CC)

The raw material of the coil coating process is long, thin strips of metal, known as coils. The Coil Coating category consists of

processes that clean, surface, and apply an organic (paint) coating to the coil. An example of a coil coating operation is the manufacture of

soft drink cans with names and logos painted on coils which are then sealed to form cans.

COPPER FORMING (CF)

Copper Forming is the physical reforming of copper by processes similar to those described above under Aluminum Forming.

ELECTRICAL AND ELECTRONIC PRODUCTS (EE)

The Electrical and Electronic Products category encompasses the manufacture of a broad array of electrical and electronic

products. Major regulated products include the manufacture of semiconductors (transistors) and cathode ray tubes, such as television picture

tubes.

ELECTROPLATING AND METAL FINISHING (EM)

Electroplating is a process by which metals in a solution are deposited on an object immersed in the solution by the use of electricity.

The immersed object is known as the basis. An example of electroplating is gold plating. Instead of making an object entirely out of gold,

it is made of another material and only coated with gold., This is done by immersing the object in a solution of gold. When electricity is passed

through the solution and object, the gold is deposited in a thin layer on the object.

In addition to the electroplating process, the Federal regulations also apply to five other related operations: electroless plating,

anodizing, coating, chemical etching and milling, and printed circuit board manufacturing. A facility should be considered regulated by the

Electroplating and Metal Finishing category if it does electroplating or any of the five operations listed above. Additionally, if a facility performs

a metal finishing operation (i.e., painting, polishing, decreasing, welding, etc.) in addition to one of the six operations described above, these

metal finishing operations would also be subject to Federal regulation and National pretreatment standards.

INORGANIC CHEMICALS MANUFACTURING (IC)

Inorganic Chemicals Manufacturing encompasses the manufacture of all chemical compounds not containing any carbon. The

number of such chemicals manufactured is vast, however, Federal regulations of inorganic chemicals manufacture has focused on 66

subcategories of chemicals. Known or suspected manufacturers of any inorganic compounds such as hydrochloric acid, sulfuric acid, chrome

pigments, or iodine should be identified by this category until additional information can be collected to determine the applicability of the

regulation.

IRON AND STEEL (IS)

The Iron and Steel category includes all processes used in the manufacture of iron and those additional processes used to

manufacture steel, including forming and casting processes used to create a finished product.

LEATHER TANNING AND FINISHING (LT)

The Leather Tanning and Finishing category includes facilities that convert animal hides and skins into leather. Facilities that

purchase leather for the manufacture of leather products are not to be included in this category.

METAL MOLDING AND CASTING (MM)

The raw materials in this category are aluminum, copper, iron, lead, magnesiurn, or zinc. These metals are melted and poured or

forced into a mold which, when cooled, produces a cast intermediate or final product. Foundries are an example of the type of industry that

would be grouped in this category.
E-4

NONFERROUS METAL FORMING (NF)

The Nonferrous Metals Forming category includes two major groups: forming and production. The category includes forming of

all metals and alloys that do not contain iron as the primary metal and that are not covered by a specific regulation (i.e., aluminum forming and

copper forming). The forming processes used in this category are similar to those described under Aluminum Forming. T'he category also

includes the production of metal powders through mechanics means such as milling.

NONFERROUS METAL MANUFACTURING (NM)

This category is made up of facilities that produce metals from ore concentrates or that recover metals from recycled metallic

wastes, such as aluminum cans or lead batteries.

ORGANIC CHEMICALS, PLASTICS AND SYNTHETIC FIBERS (OC)

This category covers the manufacture of an exceptionally broad range of industrial organic chemicals (chemicals containing at least

one carbon molecule), plastics, and synthetic fibers. Generally, the manufacture of organic chemicals, plastics, and synthetic fibers can be

assumed to be covered by this category when the manufacturing facility is identified by SIC codes 2865, 2869, 2821, 2823, and 2824.

PESTICIDE CHEMICALS (PC)

The Pesticide Chemicals category includes the manufacture, formulation, and packaging of chemicals whose primary purpose is

to control or destroy undesirable plants and animals. The pesticide chemicals category is broader than most categories in that it includes

formulation and packaging of pesticides and is not limited to manufacture.

PETROLEUM REFINING (PR)

The Petroleum Refining category includes facilities that produce petroleum products such as gasoline, heating oil, diesel fuel, and

asphalt from crude oil by physical separation and/or chemical reaction processes.

PHARMACEUTICAL MANUFACTURING (PM)

The Pharmaceutical Manufacturing category includes the manufacture of all chemicals of feed or medicinal grade that have a

therapeutic value. The manufacture of such chemicals is included within the category regardless of whether it was produced by chemical

synthesis, fermentation, extraction from natural sources, or other processes.

PORCELAIN ENAMELING (PE)

Porcelain enameling is the process by which a ceramic or fused silicate finish is applied to a basis metal product. The Porcelain

Enameling, category regulates processes including the operations by which the metal basis is prepared for enameling and the operations by

which the ceramic or fused silicate is applied to the basis. Examples of basis materials include bathtubs, sinks, and other bathroom items.

PULP, PAPER AND PAPERBOARD AND BUILDERS’ PAPER AND BOARD MILLS (PP)

These categories are defined as including industries identified by one of the following four SIC classifications: 2611 facilities

engaged in making pulp (a mixture of wood or other fibers with water which is used as a raw material for most paper manufacture); 2621 paper

mills (facilities that produce paper) that do not primarily manufacture building paper; 2631 mills manufacturing paperboard (e.g., cardboard,

chipboard, and pressboard); and 2661 building paper and board mills including production of paper and paperboard used in building.

STEAM ELECTRIC (SE)

The Steam Electric Power Generating category includes facilities engaged in the production of steam to generate electricity for

distribution and sale. This category does not pertain to facilities that generate electricity for onsite use.

TIMBER PRODUCTS PROCESSING (TP)

The Timber Products Processing category includes a broad range of facilities which produce lumber, wood, and basic board

materials. It includes saw mills, millwork and finishing plants, veneer and plywood plants, and wood processing plants (plants at which

creosote or other materials are saturated into the wood as a preservative). The category also includes facilities that manufacture particleboard,

hardwood, and insulation board.
APPENDIX F

REFERENCE DOCUMENTS FOR FLAMMABILITY, EXPLOSIVITY, AND HEALTH

HAZARDS OF CHEMICALS
REFERENCES

1990–1991 Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure

Indices, American Conference of Governmental and Industrial Hygienists (ACGIH), 1990.

Recommended Exposure Limits, National Institute for Occupational Safety and Health (NIOSH)

Permissible Exposure Limits, Occupational Health and Safety Administration (OSHA), 29 CFR 1910.1000–

1910.1101

Guidance to Protect POTW Workers from Toxic and Reactive Gases and Vapors, EPA 812-B-92-001, June

1992

Guidance Manual on the Development and Implementation of Local Discharge Limitations Under the

Pretreatment Program, EPA, December 1987

Flammable, Combustible Liquids and Gases in Manholes, Sewers, and Similar Underground Structures,

1982 by NFPA

NFPA 49 – Hazardous Chemicals Data, National Fire Protection Agency

Pocket Guide to Chemical Hazards (NIOSH 90-117), National Institute for Occupational Safety and Health

(NIOSH)

Safety and Health in Wastewater Systems, Manual of Practice 1, Water Pollution Control Federation (now

Water Environment Federation), 1983
APPENDIX G

HAULED WASTE ORDINANCE LANGUAGE

EXAMPLE
St. Louis MSD Ordinance

ORDINANCE NO. 10082

AN ORDINANCE, repealing Ordinance No. 8102, as adopted June 15, 1990, and adopting a new

ordinance in lieu thereof regulating the discharge to the facilities of The Metropolitan St. Louis Sewer

District of water or liquid waste which has been removed and transported from any pit, sump, holding tank,

septic tank, wastewater treatment facility or industrial facility.

Section One – Ordinance No. 8102, as adopted June 15, 1990, is hereby repealed.

Section Two – Discharge of Hauled Waste

A. No person shall discharge or cause to be discharged to any public sewer or to any public sewer facility

or to any private sewer tributary to any public sewer any water and/or waste which has been removed

and transported from any pit, sump, holding tank, septic tank, wastewater treatment facility or

industrial facility except as authorized by this ordinance. Such water and/or waste is hereinafter

referred to in this ordinance as hauled waste.

B. Under no circumstance may hauled waste which is hazardous waste, as defined in 40 CFR 261 or

10 CSR 25-4.261, be discharged to District facilities.

C. Hauled waste of commercial or industrial origin or hauled waste of unusually high strength may be

discharged only if the original source of the waste has received written approval from the District. The

original source of such waste shall submit, to the District's Department of Environmental Compliance,

an application for Special Discharge, on a form provided by the District, along with such

supplementary information as the District may require. The District will review the application and

will determine acceptability for discharge of the waste based on the Application and Acceptance

Criteria for Special Discharges developed by the District.

Section Three – Waste Transporter Authorization

Only District authorized waste transporters may discharge hauled waste at District facilities.

A. Any person wishing to obtain authorization to discharge hauled waste at District facilities shall submit

a Waste Transporter Identification application on a form provided by the District complete with all

supplementary information as specified on the application form and in this section. If approved, the

applicant will be assigned a Waste Transporter Identification Number. The following supplementary

information shall be included with the application:

(1) Proof of comprehensive general liability and auto liability insurance which includes the District

as an additional insured and includes provisions for informing the District ten days prior to the

time of policy cancellations or renewals. Applicants shall maintain general liability insurance and

automobile liability insurance in such amounts as the District may, from time to time, deem

appropriate.

(2) A list of the vehicles applicant has in service for transportation of liquid waste. The list shall

include the make and model, the state of registration, the state vehicle license number and the

tank volume, in gallons, for each vehicle operated.

(3) Proof that waste transporter vehicles which are to discharge at District facilities are in

compliance with all applicable State of Missouri, City of St. Louis and/or St. Louis County laws

and regulations applicable to waste transporters within the jurisdictions within which applicant
G-2

operates. Waste transporters operating within St. Louis County shall provide a St. Louis County

Department of Health Permit Number for each vehicle to be operated within St. Louis County.

(4) Volumes and types of waste transported each year for the last three years. A new business shall

submit an estimate of volumes for the first year.

B. Any person who has been granted authorization to discharge hauled waste at District facilities shall

annually provide proof to the Director of continued liability insurance and proof of continued

compliance with applicable State of Missouri, City of St. Louis and/or St. Louis County laws and

regulations.

C. The District may rescind a transporter's authorization to discharge hauled waste if the transporter is

found to be in violation of the provisions of this ordinance or other District ordinances.

Section Four – Waste Discharge Location

A. Any hauled waste which is acceptable to the District may be discharged only at the District's Hauled

Waste Receiving Station located at:

Bissell Point Wastewater Treatment Plant

10 East Grand Avenue

St. Louis, MO 63147

Hauled waste may be discharged at this location only between the hours of 7:00 AM and 5:30 PM,

Monday through Friday, excluding holidays, and between the hours of 7:00 AM and 12:00 noon on

Saturday.

B. Under emergency conditions, as determined by the Director, hauled waste may be discharged at such

alternate locations and under such conditions as the Director determines are appropriate.

Section Five – Hauled Waste Receipts and Samples

A. No person shall discharge or cause to be discharged hauled waste without presenting a completed

Hauled Waste Receipt form to the receiving station attendant at the time of discharge. The Hauled

Waste Receipt shall be on a form provided by the District and shall fully identify, to the satisfaction of

the attendant, the source and nature of the waste.

B. Hauled waste subject to the prior approval provisions of Section Two of this ordinance may be

discharged only upon verification by the attendant that such prior approval has been granted.

C. A sample of each load of hauled waste to be discharged shall be collected by the receiving station

attendant and appropriate screening analyses performed prior to discharge being allowed. The sample

will be retained and submitted to the District's Department of Environmental Compliance laboratory

for such further analyses as deemed necessary to determine its compliance with the requirements of the

District's sewer use ordinance and applicable local, state and federal regulations. In the event this

hauled waste is found to be in violation of said ordinance or regulations, approval to discharge this

water or waste to District facilities may be revoked and any damages incurred by the District will be

charged to the person discharging said water or waste.

Section Six – Conditions of Discharge
G-3

Any person granted authorization under Section Three to discharge hauled waste at the point designated

herein and in possession of proper Hauled Waste Receipts assents to the conditions hereinafter stated and

agrees to be bound by his conditional obligations and duties, to wit:

(1) The transporter will comply with all District regulations and follow the directions of District

employees while on District premises.

(2) The transporter agrees to indemnify and to save the District harmless from any and all damage

and expenses which may be suffered by it by reason of any or all of his acts done on its premises,

including but not as a limitation, the discharge of the aforesaid hauled waste which violates any

standard or standards of the District's sewer use ordinance.

(3) The transporter will, in the event of spills or leakage of hauled waste on the District's premises,

as a result of his acts or faulty equipment, appropriately clean, to the satisfaction of the attendant

on duty, the area involved.

Section Seven – District Refusal of Waste

The District has the right to refuse to accept the discharge of any hauled waste brought to the Hauled

Waste Receiving Station if, in the opinion of the attendant on duty, based on a review of the Hauled Waste

Receipt form, District records and the screening analyses:

(1) The waste does not meet the conditions under which a prior approval was granted, or

(2) The waste could cause operational and maintenance problems, be detrimental to the health of

District employees or cause violations of the District's NPDES Permit or any other City, State or

Federal environmental laws and regulations.

Section Eight – Discharge at Other Locations Unlawful

The discharge of hauled waste into any District facility, manhole or other location not approved for such

discharge shall be considered unlawful and the person responsible for such discharge shall be deemed guilty

of a misdemeanor and upon conviction thereof shall be fined not more than One Thousand Dollars

($1,000.00) or imprisoned in the County Jail or County Workhouse, as the case may be, for not more than

one (1) year, or by both such fine and imprisonment for each such violation.

Section Nine – Fees for Discharge of Hauled Waste

A. Waste Transporters shall pay a fee for hauled waste discharged pursuant to this ordinance based upon

the non-residential wastewater user charges in effect at the time of the discharge. The fee for each

discharge will be calculated based upon the full volume of the transport vehicle. Waste transporters

will be billed by the District monthly.

B. The original source of a hauled waste of unusually high strength, subject to the prior approval

provisions of Section Two of this ordinance, shall pay an additional fee, as agreed upon, between the

original source of the waste and the District. This additional fee shall be billed by the District to the

original source following receipt of the waste.
G-4

Section Ten – Charge for Late Payment

If any charges billed are not paid by the due date indicated on any bill rendered, then an additional late

payment charge, based on the percentage established by ordinance for late payments of wastewater user

charges, is hereby imposed for each month or portion thereof the bill remains unpaid beyond the due date.

Section Eleven – Termination of Service for Nonpayment

A. When any waste transporter monthly charge has not been paid and has been delinquent for more than

fifteen days after the due date, then the District may refuse to accept any further waste discharges

from that transporter.

B. When any bill rendered to a source of hauled waste subject to the high strength waste charges in

Section Nine of this ordinance has not been paid and has been delinquent for more than fifteen days

after the due date, then the District may refuse to accept any further waste discharges from that

source.

Section Twelve – Severability

The invalidity of any section, clause, sentence or provision of this Ordinance shall not affect the validity of

any other part of this Ordinance which can be given effect without such invalid part or parts. 

Section Thirteen – Effective Date

This ordinance shall become effective on June 1, 1997.

The foregoing Ordinance was adopted May 8, 1997. 
APPENDIX H

HAULED WASTE MANIFEST FORM

EXAMPLE
NON-HAZARDOUS WASTE MANIFEST

1. Generator's US EPA ID Number

2. Generator's Name and Mailing

3. Generator's Phone ( )

4. Transporter Company Name 5. US EPA ID Number

 

6.Transporter's Phone

7. Designated Facility Name and

 Site Address

8. US EPA ID Number 9. Facility's Phone

10. Waste Shipping Name and Description 11. Containers

 No. Type

12. Total

 Quantity

13. Unit

 Wt./Vol.

14. Additional Descriptions for Materials Listed Above 15. Handling Codes for Wastes Listed Above

16. Special Handling Instructions and Additional Information

17. Printed/Typed Name of Generator Signature Month Day Year

18. Transporter Acknowledgment of Receipt of Materials

 Printed/Typed Name Signature Month Day Year

19. Discrepancy Indication Space

20. Facility Owner or Operator : Certification of receipt of waste materials covered by this manifest except as noted in Item 19.

 Printed/Typed Name Month Day Year